IMC:8/6/05
ATEX Standing Committee 30/6/05
Comments on ExNB Clarification Sheets
1. General comments on ExNB Clarification Sheets
The objective of ExNB is to assist in the harmonious implementation of directive 94/9/EC, with particular reference to the technical issues encountered when applying the conformity assessment procedures including type examination, quality assurance assessment and product verification. Much of its work concerns clarification of requirements contained in harmonized standards with reference to the EHSRs where necessary. ExNB also assists the ATEX Standing Committee on matters relating to the clarification of the [legal?] requirements of the directive where the knowledge and experience of the NBs can contribute to the committee’s considerations.
ExNB produces Clarification Sheets which set out the agreed view on particular technical requirements and how conformity with them is to be assessed. The Clarification Sheets are sent to the Standing Committee for noting. They are not endorsed by the committee but there is an opportunity for the committee to consider whether the issues are within the competence of ExNB or should be taken into the committee’s responsibility.
Issues such as which products fall within the scope of the directive, the definition of the conformity assessment procedures and the wording of the conformity assessment documents are the responsibility of the Standing Committee. Problems encountered by the NBs in these areas must be referred to the committee by ExNB. ExNB may suggest possible answers but it is for the committee to decide and to publish its findings in the form of Consideration Sheets or by revising the ATEX Guidelines.
NBs are working in a dynamic market and need rapid answers to questions raised by their customers in order that the customers’ products may be placed on the market without undue delay. It will be necessary for individual NBs to arrive at their own interim interpretations of the directive and the supporting standards while seeking guidance from their national authorities, ExNB or the Steering Committee. A system is needed which can respond quickly to meet these demands so as to minimize distortions to the market which can be caused by differing interpretations between NBs.
2. Comments on particular clarification sheets
ExNB/99/082/CS: Instructions to be checked by NB – necessary to specify this level of detail, but is this in the realm of a procedural issue which is under the jurisdiction of the SC?
ExNB/99/100/CS: Accepting work from bodies outside EU – procedural?
ExNB/00/06/26/CS: Wording of EC type examination cert. – procedural?
ExNB/01/100/P: Quality system criteria – reference to EN 13980 as superceding ExNB/98/96/005DS.
ExNB/02/109/CS: EC type examination of assemblies – partly overtaken by Ed 2. of ATEX Guidelines, as regards assemblies, but the combined equipment/protective system situation is not addressed (?).
ExNB/02/112/CS: Gas detectors with measurement function – is this covered in Ed 2 Guidelines? Yes in relation to safety devices.
ExNB/02/114/CS: Relevant information communicated by NBs – current discussions could lead to a change in the practice as recommended by this CS.
ExNB/99/084/CS: Measuring function – See ATEX Guidelines Ed.2, 3.10
ExNB/00/06/20/CS: Cat 3 certificate – this sheet is proposed to be withdrawn as coming within authority of SC.
ExNB/00/036/CS: X-marking temperature – This is a subject of application of the harmonized standards and should remain within the authority of ExNB – may have been superseded by revision of standards.
ExNB/04/161/CS: QA audits of instructions – this is a subject of the application of a harmonized standard and should remain within the authority of ExNB
ExNB/98/06/002/CS: Bearings of electric motors – reference is needed to EN13463. For a Cat 2 motor, NB examination of the electrical ignition risks and manufacturer examination of mechanical ignition risks should suffice. ATEX SC to discuss.
ExNB/98/06/006/DS: Conformity to type notification – ATEX SC should deal with this as it is a procedural matter. ExNB can advise on practical implementation issues.
ExNB/98/06/009/CS: Revision of standards and effect on certificates – partly overtaken by current discussions on the subject, but the question of evidence of conformity of components incorporated in equipment is not being dealt with (?)
ExNB/98/068/CS: Acceptance of manufacturers’ test results – This is a procedural issue which should be handled by the ATEX SC, with advice from ExNB.
ExNB/99/01/071/CS: Listing of certificates on QA Notifications - This is a procedural issue which should be handled by the ATEX SC, with advice from ExNB.
ExNB/00/28/CS: Language of certification label - This is a procedural issue which should be handled by the ATEX SC, with advice from ExNB.
ExNB/00/035/CS: Certificate for flameproof enclosures - This is a procedural issue which should be handled by the ATEX SC, with advice from ExNB.
ExNB/00/040/CS: Certification of equipment for use outside “atmospheric conditions” – This is a scope issue which is dealt with by Ed.2 of the ATEX Guidelines.
ExNB/00/93/CS: Tests required for unstable detonation flame arresters – this might be considered a matter for ATEX SC as it deals with what should be stated on a certificate, but the issues dealt with are mainly technical, so should remain the province of ExNB.
ExNB/01/103/CS: Certification of protective systems – the content of this sheet should be incorporated in the ATEX Guidelines, modified as considered necessary by ATEX SC.
ExNB/04/160/CS: Radio frequency power limitation – this is the CS relating to 2-way radios.
ExNB/98/06/005/DS: Assessment schedule for Annexes IV, VI and VII – superseded by EN 13980.
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