Small shop need homemade table lamps PAT tested

[stillp]

John (both of you) it does not matter if the lamps are for sale or not, using them in the shop is still considered "placing on the market". You might not think that logical, but it's what the law says.

I see

Is that just because it's a shop, or does everything I've constructed for use in my home count as "having been placed on the market" and therefore should be declared as being in conformity with the LV and EMC Directives (and undoubtedly other things, too!)??

Kind Regards, John

The law is not very precise in this area; certainly as the shop is a place of work there are more regulations applicable than in the home, but I'm aware of Trading Standards enforcement action against a home owner who had constructed some equipment for his own use.
The machinery Directive is more precise; if you make a machine for your own use then it is, at some stage, "placed on the market".

 

[stillp]

So if you build a house and fit a lamp holder to the ceiling the house needs testing for EMC as it is the lamp holder? I don't think so!

Umm... NO!
Did I say (or imply) that?
If you were say to build an inverter to drive your lights, and install that in your house, you'd have to ensure the inverter complied and make a declaration of conformity., just as volume manufacturers have to.

 

[JohnW2]

The law is not very precise in this area; certainly as the shop is a place of work there are more regulations applicable than in the home, but I'm aware of Trading Standards enforcement action against a home owner who had constructed some equipment for his own use.

Oh Dear! ... and how on earth did Trading Standards get involved (or even become aware that this equiment had been constructed)?

The machinery Directive is more precise; if you make a machine for your own use then it is, at some stage, "placed on the market".

Another potential 'Oh Dear'. What counts as 'a machine' - anything 'mechanical'? If so, they'd have a field day in my house.

This seems to be a serious can of worms, probably a case of well-intentioned laws and regulations being invoked beyond the point which makes sense. I'm trying hard not to use the word 'silly'!

Kind Regards, John

 

[ericmark]

When I took my RAE many years ago I was trained how to limit interference, the same when I took my degree in electrical and electronic engineering, as an auto electrician I was also trained how to reduce interference but as a simple mains spark non of the courses I have done have included any training as to how to measure or reduce interference. Yes I have a wave meter but I would guess that is unusual for any mains spark never mind some one just trained to PAT test.

I am permitted to build and use electronic equipment including transmitters as long as I ensure they do not interfere with others this is what my licence is for. I am not required to get this equipment tested by any third party but if asked by the licensing authority I must stop using it. That also includes any commercially built equipment.

It would seem that in the USA Chinese built radios without the federal seal of approval can't be used however that is not the case in the UK we are still allowed to build our own from scratch and use them. One has to be very careful with internet so often it picks up USA rules which don't apply here and other way around.

73 GW7MGW, VP8BKM, VR2ZEP

 

[stillp]

The law is not very precise in this area; certainly as the shop is a place of work there are more regulations applicable than in the home, but I'm aware of Trading Standards enforcement action against a home owner who had constructed some equipment for his own use.

Oh Dear! ... and how on earth did Trading Standards get involved (or even become aware that this equiment had been constructed)?

The machinery Directive is more precise; if you make a machine for your own use then it is, at some stage, "placed on the market".

Another potential 'Oh Dear'. What counts as 'a machine' - anything 'mechanical'? If so, they'd have a field day in my house.

This seems to be a serious can of worms, probably a case of well-intentioned laws and regulations being invoked beyond the point which makes sense. I'm trying hard not to use the word 'silly'!

Kind Regards, John

Trading Standards were involved following a complaint, presumably about disturbances emitted by the equipment.

There's a definition of "machinery" in the machinery directive (and repeated in the Supply of Machinery (Safety) Regulations 2008.

I don't imagine that the lawmakers are much concerned whether you think the regulations are 'silly' or not. Their intent is clearly that an individual has the same liabilities as a large organisation

 

[JohnW2]

I am permitted to build and use electronic equipment including transmitters as long as I ensure they do not interfere with others this is what my licence is for. I am not required to get this equipment tested by any third party but if asked by the licensing authority I must stop using it. That also includes any commercially built equipment.

Indeed - same here. Like you, I was not aware of the need to 'declare conformity' in relation to equipment I use, merely of a 'Part P-like' requirement 'to take reasonable steps to avoid causing interference' and, as you say, to stop using the equipment if so requested by the licensing authority.

Taken to its absurd conclusion, this 'requirement to declare conformity' could be argued to extend to anything electrical/electronic which involved anything other than unvarying DC currents!

At least with the EMC Directive, there is the fact that others could be affected, so I can see some arguments. In the case of the LV Directive, I struggle even more to understand.

Kind Regards, John

 

[footprints]

Oh dear! I made a table lamp in woodwork class in 1962, phew! thank goodness we threw it out when clearing my mums house...........

 

[JohnW2]

Trading Standards were involved following a complaint, presumably about disturbances emitted by the equipment.

Ah, I see - that makes sense, and has always happened in one way or another (although not, in the past, dealt with by Trading Standards). Enforcement action requiring rectification of a source of interference is fair enough. I thought you were talking about action taken because of 'failure to declare conformity' (in the absence of the equipment causing any problems), which is the concept which surprised me.

Kind Regards, John

 

[ericmark]

Some of the rules do seem daft but I have also used them to force my point. Went to a place with loads of plastic blanks put in the sockets which I binned I stated no BS number then you must not use and if they could find sockets blanks with BS number then they could used them. Seems non of the so called socket safety things have a BS number so now not used.

 

[stillp]

Taken to its absurd conclusion, this 'requirement to declare conformity' could be argued to extend to anything electrical/electronic which involved anything other than unvarying DC currents!

At least with the EMC Directive, there is the fact that others could be affected, so I can see some arguments. In the case of the LV Directive, I struggle even more to understand.

No, now you're being silly. You don't have to take anything to a conclusion, absurd or otherwise, just read the scope of the regulations.

I'm sorry you are struggling to understand, but home-made LV equipment has been know to cause harm, not necessarily to the person who made the equipment. Most of the harm from non-compliant LV equipment seems to result from fire and combustion products, which are included within the LVD.

Eric, I believe the exemption form type testing for radio amateurs applies only to disturbances emitted from the equipment, not the electrical safety thereof, but if you know otherwise please let me know.

 

[JohnW2]

No, now you're being silly. You don't have to take anything to a conclusion, absurd or otherwise, just read the scope of the regulations.

Needless to say, I wouldn't regard it as silly! The problem, of course, is that I have not read the regulations in question, about scope or otherwise. However, you presumably have, so maybe you could enlighten me. As I said, in theoretical terms, any equipment which involves varying currents (whether varying DC, AC of any waveform or any sort of pulsed/ intermittent current) has the theoretical capacity to produce electromagnetic radiation - so I suppose it's a question of where the regulations have chosen to 'draw the line'.

I'm sorry you are struggling to understand, but home-made LV equipment has been know to cause harm, not necessarily to the person who made the equipment. Most of the harm from non-compliant LV equipment seems to result from fire and combustion products, which are included within the LVD.

I suppose the main thing which is confusing me is that the risks to which you refer apply at least as much to the fixed wiring of an electrical installation as to any equipment powered from that installation. For the past 9 years, we have had 'Part P' which requires reasonable steps to be taken to prevent injury to certain people (but not property), but I have never heard it suggested that there is a requirement to make a declaration of conformity with the LV Directive (or EMC Directive) in relation to work on the fixed wiring. Have I missed this?

Eric, I believe the exemption form type testing for radio amateurs applies only to disturbances emitted from the equipment, not the electrical safety thereof, but if you know otherwise please let me know.

I think that eric was, indeed, probably talking only about EMC, and I think what he said about that was correct. Having said that, my amateur radio licence, issued in 1963, presumably pre-dates most of the regulations and directives were're discussing by many decades, so I might well not be up-to-date with its conditions and associated regulations!!

Kind Regards, John

 

[stillp]

John, you can Google as well as I can, so I'm not going to post sections of the regulations for you, since you'll only raise issues which are in the bits I haven't posted, until I've posted the entire regulations plus the official guidance.

No, you haven't missed anything, but why bring fixed wiring into a discussion about equipment? The fact that there might be similar risks does not mean they're covered by the same legislation.

The exemption for amateur radio equipment came about in part because 'hams' are among the most likely people to discover and report EMI, so they were considered to be largely self-policing. As Eric said, there were/are some concerns about a "conflict of interest" between the earthing requirements for performance and those for safety, but they only very rarely cause a problem for those not directly involved.

 

[JohnW2]

No, you haven't missed anything, but why bring fixed wiring into a discussion about equipment? The fact that there might be similar risks does not mean they're covered by the same legislation.

Fair enough. I suppose I'm being naive in assuming that, since both pose similar risks (in relation to 'fire and combustion products'), the legislation in relation to both should impose similar requirements.

The exemption for amateur radio equipment came about in part because 'hams' are among the most likely people to discover and report EMI, so they were considered to be largely self-policing.

I suppose that makes sense. As I implied in my previous post, most of my days of constructing and using amateur radio equipment probably pre-dated any of this legislation by a big margin, so I suspect that there was probably nothing to be exempted from in those days! However, we certainly were discovering, reporting and dealing with EMI (which in those days we usually called 'TVI', since analogue, often VHF, TVs were almost invariably the 'victims') back then! There are, of course, now dramatically more things to interfere with.

Kind Regards, John

 

[stillp]

No, you haven't missed anything, but why bring fixed wiring into a discussion about equipment? The fact that there might be similar risks does not mean they're covered by the same legislation.

Fair enough. I suppose I'm being naive in assuming that, since both pose similar risks (in relation to 'fire and combustion products'), the legislation in relation to both should impose similar requirements.

Ah now there you're being naive in confusing risks and hazards, but let's not go there!

 

[JohnW2]

No, you haven't missed anything, but why bring fixed wiring into a discussion about equipment? The fact that there might be similar risks does not mean they're covered by the same legislation.

Fair enough. I suppose I'm being naive in assuming that, since both pose similar risks (in relation to 'fire and combustion products'), the legislation in relation to both should impose similar requirements.

Ah now there you're being naive in confusing risks and hazards, but let's not go there!

As I think you know only too well, I'm one of the last people who ought to confuse the two

[for the benefit of the wider readership, at least from the perspective of the HSE, risk is the probability of harm resulting from a hazard, taking into account any factors which mitigate the risk posed by the hazard. However, this terminology can cause confusion in some circles, since statisticians use 'hazard functions' and 'hazard ratios' to describe 'event rates' (essentially 'risks')]

Whatever, my belief (maybe wrong!) is that not only do fixed wiring and items of equipment present some similar hazards, but that fixed wiring probably results in at least as much risk (relating to 'fire or combustion products') as does equipment!

Kind Regards, John