Change in safety regulations
Do you have some evidence your non-declared luminaires comply with AS/NZS 60598 ?
Queensland Regulations now require this evidence. Its not a new change but is so subtle it has slipped under the radar.
When clients made enquires on legislation effecting non-declared luminaires, LEDLab used to respond
“Whilst we can help you with testing, the State Government Acts are vague on the requirements”
In fact NSW legislation is still vague.
The Electricity Consumer Safety Regulation 2006 says.
That is it still calls up AS/NZS 3820:1998 which was slack. The 2009 edition was tighter but still it does NOT say. Compliance with clause 4 “SHALL” be demonstrated by compliance with AS/NZS 60598.
Instead it does say “Generally” compliance with Clause 4 “CAN” be demonstrated by compliance with AS/NZS 60598.
In this way you are “sort of” allowed to use alternate means to demonstrate safety to what is described in Clause 4.
If your product never hurts anybody, historically you were not prosecuted for not having an AS/NZS 60598 Test Report. If you did have problems Clause 9 of the Electricity Consumer Safety would indicate you can test it later.
This has changed in Queensland.
No longer is 3820 referring to 60598. The later is referred to first in the actual Act and Regulation.
Whilst the requirements on Level 2 (simple portable luminaire) and 3 (declared) are of course tighter, LEDLab recommends all normal luminaires be treated as Level 2. As although Queensland’s Act does not require an SDoC and compliance folder, how do you produce (within 10 days) evidence of complying with AS/NZS 60598 without such things. Remember with regulations, in court, you are presumed guilty till you prove you are innocent.
Now with Level 2 products
If you have such a person working for you and they have the time, start this process.
If not contact LEDLab as we have many suitably qualified people who can help you with the AS/NZS 60598 Test Reports and declarations.
One final thing. If you supply the luminaire with plug and cord, you must have a declaration.
The above applies at any level.
David Ford – 0409661972