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  1. kronin323

    kronin323 Font of Useless Knowledge Premium Member

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    I'm sure many of you already know what this is, but for those who don't, basically it's a conformity marking for certain products sold within the European Economic Area, which declares that the product meets applicable standards.

    So I wondered, why are sunglasses a product that requires a CE mark?

    The answer: they fall under the category of Personal Protective Equipment (PPE).

    So I wondered, why are they considered PPE? Most of them aren't sold as safety glasses.

    The answer to that one isn't as clear - PPE is defined as:

    "Equipment intended to be worn or held by a person for protection against one or more risks for his or her health or safety that is placed on the market separately or combined with personal non-protective equipment."

    Which would make sense, since they protect your eyes from unhealthy UV. But there is also a statement about which PPE are out-of-scope of the regulation, with one of those exceptions being:

    PPE "intended for private use to protect against atmospheric conditions that are not of an extreme nature."

    I would think that would apply to sunglasses, but apparently not.

    And that leads to the open question for this thread...

    Maybe knowing what the specific standards sunglasses must meet for CE are would illuminate why they are considered in-scope PPE. But I can't find what those specific standards are.

    Does anyone know? @Rustpot?
     
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  2. Rustpot

    Rustpot M Frame Lover Premium Member

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    I'm flattered you point to me, specifically. I'm more familiar with the CE directives relating to EM emissivity/radiation, machinery safety, low voltage directive, etc. from the machines at work.

    Looking at this from a cursory glance;

    89/686/EEC is the directive on PPE. Chapter II, Article 8;


    CHAPTER II CERTIFICATION PROCEDURES Article 8
    1 . Before placing a PPE model on the market, the manufacturer or his authorized representative established in the Community shall assemble the technical documentation referred to in Annex III so that this can, if necessary, be submitted to the competent authorities.

    2. Prior to the series production of PPE other than those referred to in paragraph 3 , the manufacturer or his authorized representative established in the Community shall submit a model for EC type-examination as referred to in Article 10.

    3 . EC type-examination shall not be required in the case of PPE models of simple design where the designer assumes the user can himself assess the level of protection provided against the minimal risks concerned the effects of which, when they are gradual, can be safely identified by the user in good time. This category shall cover exclusively PPE intended to protect the wearer against:
    — mechanical action whose effects are superficial (gardening gloves, thimbles, etc.),
    — cleaning materials of weak action and easily reversible effects (gloves affording protection against diluted detergent solutions, etc.),
    — risks encountered in the handling of hot components which do not expose the user to a temperature exceeding 50 °C or to dangerous impacts (gloves, aprons for professional use, etc.),
    — atmospheric agents of a neither exceptional nor extreme nature (headgear, seasonal clothing, footwear, etc.),
    — minor impacts and vibrations which do not affect vital areas of the body and whose effects cannot cause irreversible lesions (light anti-scalping helmets, gloves, light footwear, etc.),
    — sunlight (sunglasses)



    So yes, sunglasses are named specifically as being subject to the PPE directive, but are considered PPE in which the designer assumes the user can determine the level of protection provided and does not need to submit models to the European Community (EC).
     
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  3. Carrera1963

    Carrera1963 Lover of Juliet Premium Member

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  4. kronin323

    kronin323 Font of Useless Knowledge Premium Member

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    I did a forum search to see if this was already explained, and one of the results was from a couple of years ago on the abbreviations thread, where you mentioned having drawers full of CE standards...

    Thanks.
     
  5. kronin323

    kronin323 Font of Useless Knowledge Premium Member

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  6. Rustpot

    Rustpot M Frame Lover Premium Member

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    The fun part is the standards are FULL of loopholes and a once-over will have your head spinning. I have to print these off when I go through them and mark sections with little tabs so I can jump back and forth. Then find another section has a nice little "must... unless... otherwise..." statement that just throws the ENTIRE thing out the window. Annex II 3.9 refers to non-ionizing radiation, but you won't find protection factor markings on sunglasses.





    3.9.1 . Non-ionizing radiation PPE designed to prevent acute or chronic eye-damage from sources of non-ionizing radiation must be capable of absorbing or reflecting the majority of the energy radiated in the harmful wavelengths without unduly affecting the transmission ofthe innocuous part ofthe visible spectrum, the perception of contrasts and the ability to distinguish colours where required by the foreseeable conditions of use. To this end, protective glasses must be so designed and manufactured as to possess, for each harmful wave, a spectral transmission factor such that the radiant-energy illumination density capable of reaching the user's eye through the filter is minimized and, under no circumstances, exceeds the maximum permissible exposure value . Furthermore, the glasses must not deteriorate or lose their properties as a result of the effects of radiation emitted under the foreseeable conditons of use and all marketed specimens must bear the protection-factor number corresponding to the spectral distribution curve of their transmission factor. Glasses suitable for radiation sources ofthe same type must be classified in the ascending order of their protection factors and the manufacturer's notes must indicate, in particular, the transmission curves which make it possible to select the most appropriate PPE bearing in mind such inherent factors of the effective conditions of use as distance to source and the spectral distribution of the energy radiated at that distance. The relevant protection-factor number must be marked on all specimens of filtering glasses by the manufacturer.





    I had a fun time trying to figure out what class a certain heat exchanger we make falls into. There's a handy chart and the pressure/volume plot had me in Section III, not Class I, Class II, Class III, Class IV. I had to pay a company $750 to tell me Section III falls under SEP (not specifically stated in the directive). SEP is "Sound Engineering Practice" and pretty much means as long as we designed to *some* standard the pressure vessel needed an accompanying certificate of design validation and COULD NOT be CE marked or have a Declaration of Conformity. Meanwhile the customer is expecting the equipment to arrive in Spain with CE markings. I explain to the sales guy, who tells his POC. The equipment gets to the Volkswagen plant and is stopped at the door since it doesn't bear CE marks and someone decided they couldn't install it. I had to call a nice man in Portugal and explain to him several times the situation.

    It all worked out in the end, but DAMN. I HATE CE
     
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  7. Rustpot

    Rustpot M Frame Lover Premium Member

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    Here's the little writeup for that example above. Took me close to 2 weeks to get this together.





    All aspects of *Company* shell and tube heat exchanger model XA0143A conform to the Pressure Equipment Directive (PED) 97/23/EC. In order for this heat exchanger to be placed in service in the European Community it must comply with this law, which became mandatory May 29, 2002.

    This heat exchanger is NOT CE MARKED. Due to the classification in Article 3, Paragraph 3 of the PED, the product of the pressure and volume (PV) does not classify this heat exchanger as requiring the CE Mark. The piping and vessel contain a Group 2 (Nondangerous) liquid and DO NOT contain gas (Nondangerous or otherwise) and are covered under Sound Engineering Practice (SEP).

    This heat exchanger, designed and constructed to the rules under ASME Section VIII Div 1, is considered safe when installed and operated according to its design parameters.

    Specifications:

    Maximum Operating Pressure: 5000 PSI (345 BAR)
    Minimum Operating Pressure: 0 PSI (0 BAR)

    Maximum Operating Temperature: 150° F (66° C)
    Minimum Operating Temperature: 50° F (10° C)

    Maximum Fluid Temperature: 150° F (66° C)
    Minimum Fluid Temperature: 40° F (4.5° C)

    Maximum Volume of High Pressure Fluid: 100 in3 (1.6 L)
    Maximum Volume of Low Pressure Fluid: 387 in3 (6.3 L)

    Safety Information
    · Do not disconnect any piping while operating or under pressure.
    · Ensure all connections are tight before starting operation.
    · Do not use if equipment is visibly damaged.
    · Discontinue operation if parameters exceed maximum or minimum values.
     
  8. kronin323

    kronin323 Font of Useless Knowledge Premium Member

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    We've had to explain how a CSA marking is as good as UL. But that's not the same as CE.
     
  9. OakleyFrankFMJ

    OakleyFrankFMJ The Legend - - Vlad the Impaler Premium Member Lifetime Member

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    My head is spinning already.
     
  10. Rustpot

    Rustpot M Frame Lover Premium Member

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    CSA is NOT as good as UL.

    Canadian UL and CSA are different entities. UL is an American convention and adopted to Canadian, but must specify C UL or C UR for components to be used. CSA is a design standards body, and to conform to CSA the ESA standards must be followed and individual machines must be tested for conformity. C UL can be justified by markings, listings, and designs, CSA/ESA cannot and must be tested.

    At least that's how I understand it.