Batteries, heat and wood

[novocaine]

Just a note, again be careful where you get your information...

People are merrily telling you to comply with the LVD... have a look at the voltage range of the low voltage directive.

Also, combining certified components together does not mean your assembly is certified and the really pants part... it’s depressingly common to find certificates themselves are out of date and invalid too.

Aidan

for the battery one, no, for the mains one, yes.

"The LVD covers health and safety risks on electrical equipment operating with an input or output voltage of between

• 50 and 1000 V for alternating current
• 75 and 1500 V for direct current

It applies to a wide range of electrical equipment for both consumer and professional usage, such as

• household appliances
• cables
• power supply units
• laser equipment
• certain components, e.g. fuses"

system integrator, your responsibility to ensure all components are suitable for use intended, existing certs go along way to do this and should form part of technical file.

edit to remove dummy throw.

 

[TheTiddles]

Hi Novocaine

I believe you are correct, however RichHox is asking about a battery powered lamp, so amongst the many other things they may need to consider LVD may not be one of them.

Aidan

 

[Sandyn]

I spent my lunch break today looking up the CE side of things. It seems that it is considered safe and professional to have a CE marking and all the conformity but it isn't necessarily a legal requirement

If you look at the majority of stuff on major web sites from the far east, it has never been certified, but still sold in the UK. Compliance comes down to 'are you willing to take the personal risk if something goes wrong'. The biggest seller on the internet shed responsibility by saying they are just a seller and could you ever find the manufacturer and prosecute?? NO CHANCE!!
It makes a complete farce of our approvals systems.
People regularly sell stuff which is not CE certified. It's not about certification, it's about product safety. Is the product you are selling safe. How did you design it, how did you test it to show it's safe.

If you look at the Low Voltage Directive, the requirement is to show a product is safe according to the relevant standards using accredited test facilities or an equivalent. It is probably impossible to find equivalent test facility which is acceptable.


For my sins, I have created a technical file for a lamp which was supplied commercially, but it was for a LED wireless access point, which meant an additional standard, 60950.

I created the file in 2019, so there may be some changes to standards and your lamp has battery supply, so may include other standards.

IEC 60950-1 Information Technology equipment-Part 1 General requirements (Not for yours)

IEC 60589-1 General requirements for the safety of luminaires

IEC 60598-2-4 Particular requirements-Section 4ortable general purpose luminaires

EN 61140 Protection against electric shock-Common aspects for installation and equipment

EN 62560 Self ballasted LED lamps

Having a technical file will not get you out of any liability should things go wrong, but what it will do is focus your attention on things to attend to, like the lamp stability test on a 6 degree slope.

If you want to go down the self certification route, get in touch.

 

[Sandyn]

People are merrily telling you to comply with the LVD... have a look at the voltage range of the low voltage directive.

Unfortunately, It's not just about electrical safety, so even if the product is apparently outside the LVD, there is a catch-all...... the general product safety directive which includes everything. You can't just say it's outside the LVD, so doesn't need to be tested. Other safety aspects apply and the GPSD, just points you back to all the same standards as if it was under the LVD. They really have it all tied up, T's crossed and I's dotted. I have looked for all the ways out of it

 

[TheTiddles]

Unfortunately, It's not just about electrical safety, so even if the product is apparently outside the LVD, there is a catch-all...... the general product safety directive which includes everything. You can't just say it's outside the LVD, so doesn't need to be tested. Other safety aspects apply and the GPSD, just points you back to all the same standards as if it was under the LVD. They really have it all tied up, T's crossed and I's dotted. I have looked for all the ways out of it

Yep, quite agree.
The fallacy we keep coming across is "we've not got time/budget to do this"... It's not optional and it's also way cheaper to design to conform or adjust your design around the regulations now, rather than fail on spurious emissions later due to that nasty switcher selected at the start because it was £5 cheaper than the other one that had all the shielding and filtering on.
I can't think of a time I've regretted getting professional advice early on compliance.
Aidan

 

[Sandyn]

The really irritating thing about compliance is all these far eastern companies selling direct into the UK without doing any testing. I have complained countless times to trading standards about unsafe products, but they don't have resources to follow things up properly. It's intended to work by self policing, and generally it works within the UK..
Proper compliance is very expensive, for a start, the standards are about £100 each which is a farce, they should be free. Full CE marking includes safety and EMC, but there are all kinds of way to bypass doing testing, for example if you make a lamp. Don't sell it with the bulb as part of the main assembly. It will come under the testable item. Supply it as an accessory, however in EMC, you would have to include the bulb during test, because you need a representative load.
Full CE testing with country deltas will come in around £10,000 to.......name your price depending on standards and what testing is required.
This adds a huge amount to the per unit cost of things sold, so how can diligent UK companies, who obtain certification, compete with Far East products sold on the web?? They can't and never will.

Anyone can sell electrical products with no certification. You will not be sent to jail for doing that, but any person selling electrical products which are unsafe must ask themselves if they are prepared to lose everything they have, should they face the full force of the law after someone is killed because of their unsafe product and could they live with themselves afterwards?

I hate being a doom and gloom person , but that is the bottom line. You can't escape your responsibilities as a seller of electrical products. A hard reality.

The slightly good news is that you can do things like self certification, but it's really impossible to do a bullet proof self certification and you will have to create a document of conformance which you will have to sign. That signature is your admission that you will take responsibility for anything which goes wrong.
Before anyone suggests disclaimers...they aren't worth the paper they are written on. You cannot disclaimer your way out of your responsibilities. You can produce samples, small batch production etc, which gets you out of having to do certification, but nothing gets you out of the requirement for a safe product, according to all the directives. The have it all tied up, but very rarely prosecute. Even when they do prosecute big companies, the fines are generally pathetic.

You generally need to set conditions of use and instructions for what not to do, for example things like , the battery lamp must never be used with an alternative power source, mustn't be used against soft furnishing, mustn't be used on a unstable stable surface and other stuff.

What compliance has done is raise the safety of products, the Far East producers will not bother getting products certified, but they often do comply with the requirements, so even if they aren't totally legal, they are of a safer standard. Fortunately not many people are killed/injured due to unsafe products and even the big companies who do full compliance make really bad mistakes, just look at all the white goods fires and product recalls.

 

[TheTiddles]

Amazon give me a voucher each time I bring a safety concern to them!

 

[RichHox]

Thanks again everyone!

Regarding my comment about heat shrink, I realised after I posted it that actually it does the opposite of dissipating it! Duh.

And yeh all of my stuff is from certified sources and companies so I can request the documents if they arent already there.

Yeh I'm going to head to the library and use the computers for their copies of the BS, but covid kind of gets in the way of that currently. Unless anyone has BS EN 60598 to hand/electronically?

I had PAT training for work about 5-10 years ago. From what I've read so far PAT is more important for work environments. Domestic appliances dont require PAT, although obviously its all about safety and the consumer, so yes. I test it with a mains source and multimeter currently.

 

[Jelly]

for a start, the standards are about £100 each which is a farce, they should be free.

I fully agree that with BSI being designated as our national standards institution, the standards should be freely available, at least within the UK... It's a total farce!

On this particular point however, there is some hope.

Most local libraries will allow online access to BS Standards, as will the vast majority of Academic Libraries (which for all the faff of registering as an "external reader" with the associated uni, are usually more convenient to use of there's one nearby).

It's not a great solution, but it's better than not having access to them at all.

 

[TheTiddles]

Yes, it’s very British...

Regulator - “You new product must comply with our standards!”

Manufacturer - “What are they?”

Regulator - “Not telling you! You must buy them to find out.”

Manufacturer - “Ok, which ones?”

Regulator - “You buy the first one and it will tell you the others you must buy”

Manufacturer - “...and will those other ones refer to further ones, that I then have to buy too?”

Regulator - “probably”

Manufacturer - “I think we’ll just re-sell an import instead”

Ten minutes later, in a brainstorming meeting at an office building in Hemel Hempstead...

Regulator - “how can we encourage more domestic manufacture?”

 

[Sandyn]

Unless anyone has BS EN 60598 to hand/electronically?

PM me
BS EN 60598-1 :2015 + A1:2018

 

[Sandyn]

Amazon give me a voucher each time I bring a safety concern to them!

I have reported so many products and got nothing!!! I'm going to complain to Amazon!!!

 

[Peterm1000]

I know not the first thing about electrical regs... However, that lamp is awesome! It would solve a particular problem for me. How do I sit outside at my garden table with pleasant lighting and no cables? I tried to find a nice LED rechargeable table light last year with no joy at all. Out of interest, what kind of price would that retail for?

 

[RichHox]

I know not the first thing about electrical regs... However, that lamp is awesome! It would solve a particular problem for me. How do I sit outside at my garden table with pleasant lighting and no cables? I tried to find a nice LED rechargeable table light last year with no joy at all. Out of interest, what kind of price would that retail for?

Thanks! I haven't decided on a price as I need to get the design fully locked down. For the battery lamp its the batteries that ramp the price up so it's looking around £50-80 with the possibility of providing a 2nd battery module so you can always have one charging.