The electro technical field is governed by a special directive, the "Low Voltage Directive" (LVD). It was established in 1973 - 20 years before the "New Approach" directives. It is considered the prototype for the concept of the "New Approach" directives. The purpose of the LVD is to ensure safety in the use of electrical equipment used within voltage ratings between 50 and 1000 Volts for alternating current and between 75 and 1500 Volts for direct current. Broadly, it covers consumer goods and equipment designed to operate within those voltage limits, including domestic electrical appliances, hand tools, lighting equipment, electric wiring, cables and piping, and installation equipment. It covers all safety aspects of this equipment, including protection from hazards of mechanical origin. The LVD specifies that the member states of the European Communities shall take all appropriate measures to ensure that only such electrical equipment may be put on the market that does neither endanger the safety of people nor that of domestic animals or property. This is assumed to be given if:
- the equipment has been constructed in accordance with good engineering practice in safety matters
- the equipment has been properly installed and maintained
- the equipment is used for the purpose the equipment was made for.
These provisions are met if the equipment complies with certain safety requirements recognized in all member states. Without prejudice to any other form of proof, the proof of compliance may be established by reference to harmonized standards which state good engineering practice. The LVD was established before CE Marking was created. CE marking is a reference to the New Approach directives generated in the past years by the European Communities. The adoption of the LVD to today's needs is done by the directive 93/68/EEC. According to the directive 93/68/EEC, the manufacturer or his authorized representative within the EU draws up the Declaration of Conformity and affixes the CE marking on the product to show conformity with the LVD and its requirements. From the time the product is put on the market, the manufacturer keeps Technical Documentation at the disposal of the relevant authorities for inspection purposes. The report is kept for a period of ten years after the product was put on the market.
The general content of the Declaration of Conformity is set out in Annex III (B) of the directive. In particular, the declaration must include:
- the name and address of the manufacturer or his authorized representative within the EU
- a description of the electrical equipment
- reference to the harmonized standards
- where appropriate, reference to the specifications on which conformity is declared on behalf of the manufacturer or his authorised representativ established within the EU
- identification of the signatory who has been empowered to enter into commitments
- the last two digits of the year in which the CE marking was affixed on the product (for the first time).
The technical documentation must contain details of the design, manufacture and operation of the electrical equipment in so far as these details are needed to assess the conformity of the electrical equipment with the requirements of the directive. Accordingly, it contains:
- a general description of the product
- design and manufacture drawings plus diagrams of components, sub-assemblies, circuits etc.
- descriptions and explanations needed to understand the above mentioned drawings and diagrams plus the operation of the electrical equipment,
- a list of the standards used, in full or in part, and a description of the solutions employed to meet the safety aspects of this directive when standards have not been applied,
- the results of design calculations and of checks carried out, etc.,
- test reports (in fact, the test reports which may be available, either established by the manufacturer or a third party).
Who must keep the technical documentation and where?
The manufacturer or his authorised representative established in the Community must keep this documentation at the disposal of the national Authorities for inspection purposes for at least ten years from the last date of manufacture of the product. The technical documentation may be kept on electronic support provided that it is easily accessible for inspection. Where the manufacturer is not established in the Community and he has no authorised representative in the Community, this obligation is incumbent upon the importer or the person responsible for placing the product on the Community market. |