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Workshop on Low Voltage Directive

Workshop on Low Voltage Directive. Prioritizing and Planning, product selection and sampling in relation to the products covered by the LVD. Why Market surveillance?. Market surveillance is essential tool for the enforcement of product legislation The purpose of Market Surveillance is:

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Workshop on Low Voltage Directive

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  1. Workshop on Low Voltage Directive Prioritizing and Planning, product selection and sampling in relation to the products covered by the LVD

  2. Why Market surveillance? • Market surveillance is essential tool for the enforcement of product legislation • The purpose of Market Surveillance is: • Ensure compliance with legislation • Establish community wide equivalent level of protection • Help to eliminate unfair competition Member States are obliged to organize and carry out Market surveillance. (Article 10 of the EC treaty)

  3. Market surveillance • Investigate (the levels of) compliance with legislation • Determine non compliances • Intervene when non compliances are found • Aim for increased levels of compliance

  4. Prioritizing & Planning • Select and perform MS activities in such a way as to make optimal use of the available resources • Dependent on the objectives and criterions defined

  5. Prioritizing and market surveillance policy development Market surveillance – Planning cycle

  6. Planning Cycle Market Surveillance Vision Governmental Product safety Policy Long term program (3 years) Short term program (1 year) Operational Activity program Evaluation Carry out Activity program

  7. Policydevelopment Market Surveillance Vision Long term program (3 years) • Vision (where do we want to be in future?) • How do we want to operate: • Consumer protection/fair competition • Enforcement/compliance assistance/education • Product, business or risk oriented approach • System oriented approach, document checks, tests or both • Strategy (How to go there) • Surveillance of the environment: • Technological developments • Legal developments • Political developments • Consumer Trends • Demographic Developments • Emerging risks • Leads to a long term strategic program (3 year period, annually updated)

  8. Long term program Market Surveillance Vision Long term program (3 years) • Sets global priorities for the next period • Indicates necessary adjustments to the organization • Adjustments in the way enforcement activities are performed • Adjustments in the fields of interest • Necessary Investments in laboratories • (Re)training of personnel

  9. Long term program -> Short term program • Examples of considerations in the long term program • Less administrative burden on business/trade and industry • More ‘compliance assistence’ • Directed by considerations of health gain • Reducing accidents and injury • also dependent on organization • Capacity for specific tasks • Laboratory capacities

  10. Short term program Long term program (3 years) Short term program (1 year) • Divide capacity between the tasks (Directives) • Guided by long term program • Aims to contribute to public health, e.g. • Centers on products that present hazards • Based on expert judgment of relative hazards of product categories and assessment of the relative risks for these fields • Makes use of analysis of accident and fire statistics • Uses information from consumer complaints • Uses information from regular inspections by field inspectors • Takes into account results from previous investigations • Weighs also concerns in society and political concerns • Takes into account the possibilities of the organization

  11. Short term program Leads to: Capacity division between the main terrains: • Machines • Electrical products • Gas appliances • GPSD products • Toys • Playground equipment and amusement rides

  12. Operational activity program Short term program (1 year) • This leads to activity program: • Detailed project descriptions • Detailed description of activities. • Which products, where to inspect, how many inspections, how many samples and which samples • What to test Operational Activity program

  13. Short term program (1 year) Operational Activity program Prioritizing for product safety Market surveillanceActivity program

  14. Activity program • Detailed project descriptions • Detailed description of activities. • Which products, where to inspect, how many inspections, how many samples and which samples, which tests

  15. Objectives • Product safety • Commonly Accepted as the main criterion for prioritization • GPSD • Consumer protection • Level Playing field • Important for trade and industry • Fair competition

  16. Prioritization • AIM: optimum contribution to increased consumer protection with available resources • Variables to consider: • Economic operators • Market surveillance methods • Products • Selection of inspection items and tests

  17. Economic operatorsWho has to comply? • According to LVD: • First Importers into EU (small scale, large scale) • Manufacturers in the EU (small, large) • According GPSD • Distributors • Retailers (small, large, chains), anybody who trades Economic operators

  18. Surveillance at the source • Manufacturer or EU importer • Maximum effect EU-wide • Distributor (or importer in Member State) • Maximum effect in Member State • Distributors lower in chain • Retail chains • Retailers Economic operators

  19. Who complies and why • Ignorant Compliers • Spontaneous Compliers • Conscious Compliers • Deliberate Breakers • Ignorant Breakers Economic operators (expert estimate for small cafeterias take-away restaurants in NL)

  20. What is influenced by Market Surveillance? Spontaneous Compliance Sanction Dimensions Control Dimensions Knowledge of the rules Sanction Probability Control Probability Cost Benefit Sanction severity Detection Probability Level of Acceptance Quality of the rules Selectivity Loyalty of the target group Informal Control Economic operators No or minimal Influence Indirect Influence Direct Influence

  21. Interventions • Ignorant breakers and compliers • Communication on requirements • Enforcement communication • Compliance assistance • Breakers • Enforcement communication • Enforcement • Sanctions Economic operators

  22. Prioritization • AIM: optimum contribution to increased consumer protection with available resources • Variables to consider: • Economic operators • Market surveillance methods (enforcement) • Products • Selection of inspection items and tests

  23. 1Inspection of compliance with administrative requirements Inspection of compliance with administrative requirements • CE marking • declaration of conformity • Third party certification when required • Advantages: • Simple, fast and cheap • No equipment required • No laboratory investigation required • Inspectors need not be highly trained • Disadvantages: • Inspection does not really focus on product deficiencies • Not directly linked to product safety Market surveillance methods

  24. 2Product inspections ‘in the field’ Limited inspection and tests of products during inspection by a field inspector • Advantages • Zooms in on shortcomings in the product • May aim at shortcomings that present hazards • Disadvantages • Possibilities for testing in the field are limited • Requires better trained inspectors • Quality assurance procedures not as good as in the lab Market surveillance methods

  25. Product inspection ‘in the field’ Example Market surveillance methods 2 Project: wall and ceiling mounted luminaires Why field tests: • Many shortcomings in previous investigations • Potentially hazardous (fire risk – electrical risks) • many companies involved, small and big • Numerous different types on offer (hundreds-thousands). • Need to test large numbers of luminaires to make an visible impression on the trade. Market surveillance methods

  26. product inspection ‘in the field’wall and ceiling mounted luminaires Selection of legal requirements (labelling) and standard requirements. Requirements should be easy to test and require little or no equipment. • EN 60598-1, par. 3.2: Marking (CE, brand, wattage) • EN 60598-1, par. 3.3. Additional information (instructions for the proper and safe use; language) • EN 60598-1, par. 4.3: Wireways: smooth and free from sharp edges, burrs, ….. • EN 60598-1, par. 5.2.10: cord anchorage • electrical safety by test finger Market surveillance methods

  27. product inspection ‘in the field’wall and ceiling mounted luminaires • Determine which legal sanctions to take for each shortcoming • Proportionality principle • Consistency • Determine which companies will be inspected • large retail chains (bulk of sales) • Training of field inspectors • technical training to recognize shortcomings • Consistency in interpretation of the requirements • Legal training Market surveillance methods

  28. product inspection ‘in the field’wall and ceiling mounted luminaires Results Appr. 60 inspections 48.000 luminaires blocked (sent back to importer / manufacturer) Percentage non compliances down from appr 30 % to 8 % when checked in a second round of inspections Market surveillance methods

  29. 3Inspections + laboratory testing For example: luminaires international project • Advantages: • Gives a more detailed impression of conformity • Can be aimed at safety relevant tests • Disadvantages • Requires expensive laboratory testing • For the same resources less product inspections Market surveillance methods

  30. 4Inspection of conformity assessment and certification files For example: Gas appliances Directive requires certification by a notified body. This leads to a file of the design of the appliance and the tests performed to assess its conformity. • Advantages: • Inspection of this file avoids doing the expensive laboratory tests • Thorough design and conformity check can be done • Plays also role in the assessment of the notified body • Disadvantages • Requires highly specific up to date knowledge of the products involved and therefore highly trained inspectors • Time intensive Market surveillance methods

  31. Prioritization • AIM: optimum contribution to increased consumer protection with available resources • Variables to consider: • Economic operators • Market surveillance methods (enforcement) • Products • Selection of inspection items and tests

  32. Prioritizing products • Typically projects are chosen based on the following criteria: • Risk assessment of the product types • Analysis of accident and fire statistics • Information from consumer complaints • Information from regular inspections by field inspectors • Results from previous investigations • Concerns in society and political concerns • Analysis of RAPEX & Article 9 Notifications • And: • Market information (brands, manufacturers, market penetration, etc.) • Consumer exposure Products

  33. Prioritizing productsArt. 9 and RAPEX notifications Products

  34. Prioritization • AIM: optimum contribution to increased consumer protection with available resources • Variables to consider: • Economic operators • Market surveillance methods (enforcement) • Products • Selection of inspection items and tests

  35. Selection of inspection items and tests • Administrative requirements • Safety relevant tests from standard • MS is not conformity assessment; not necessary to test all standard requirements • Select safety relevant tests from the standard based on: • Previous knowledge of frequency of non compliance • Costs • Ease of test Inspection items and test

  36. Example: Cross border project Luminaires 2006 • First large scale joint market surveillance project for the LVD • Organized by LVD ADCO • Project management: the Netherlands • Participants: 15

  37. Why Luminaires? • Risks: electric shock; fire risk • Accident statistics: • Hardly accidents involving lighting; some mention of fires, caused by proximity to bed clothing • High percentages of non conformity • From previous investigations (in NL up to 40%) • Many notifications in CIRCA and RAPEX (the European information exchange systems) • Within the possibilities of the organizations

  38. Scope • luminaries falling within the scope of EN 60598, part 1, 1.2.9: portable luminaires • That is: portable luminaire: luminaire, which, in normal use, can be moved from one place to another while connected to the supply. • Not: wall- or ceiling mounted and trafo-fed luminaires • Reason: increased complexity with wider scope

  39. Which requirements tested? • EN 60598-1:2004 Luminaires- General requirements and tests • EN 60598-Part 2: 1997 Luminaires: Particularrequirements -Section 4 : Portable generalpurpose luminaires • Selection of requirements that are safety relevant. • Tests of the requirements should be within the possibilities of the laboratories • Test should be inexpensive • Previous experience taken into account.

  40. Test requirements

  41. Phasing of the action • Market orientation • Identification of EU importers and manufacturers • Collect information on market shares, etc • Sampling and Administrative requirements • Select businesses for sampling, • collect samples and • Check administrative requirements • CE marking, DOC, technical file if present. • Testing against the standard requirements • Reporting

  42. Results A total of 226 luminaires was investigated • Main results: see beneath. P: pass; F1: minor shortcoming; F2: shortcoming; F3: serious shortcoming

  43. More information: PROSAFE publication: Best Practice techniques in Market Surveillance • Downloadable from: http://www.prosafe.org/read_write/file/EMARS_Best_Practice_Book.pdf

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