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Part I Section 2
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Sharp-Roxy (Hong Kong) Ltd
(Appendix 14)
Underwriters Laboratories Inc.
(Appendix 16)
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Interpretation of "Standard" under section 2, Part I of the Electrical Products (Safety) Regulation
- interpretation is in terms of the (a) British standard, (b) the European Standard, (c) the International Standard and (d) any other standards as may be accepted by the Director.
- the standards under part (d) should be clearly defined. Should not omit the Japanese Industrial Standard (JIS) and Standard of the Underwriters Laboratories Inc. (UL), which are commonly recognised standards. The JIS has a long history in Hong Kong, the effectiveness of which has already been testified and proved.
- this interpretation of "Standard" is a trade barrier from the manufacturers point of view (It would increase production time and costs to amend product design to make them compatible with the specified standards. To submit the products to EMSD for approval would also delay business activity).
- strongly advocate the inclusion of other standards, such as UL and JIS in the safety standard list, should also lay down the details for any standards to be classified under (d).
The definition of accreditation and accreditation body should be switched from the order shown. Accreditation Body must first be defined as an organization with an Mutual Recognition Agreement (MRA) with Hong Kong Laboratory Accreditation Scheme (HOKLAS) before it is used in the definition for accreditation. Otherwise, the definition for "accreditation" could be read to mean an accreditation from a body that does not have an MRA with HOKLAS.
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Part III Section 8
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Underwriters Laboratories Inc.
(Appendix 16)
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The wording in 8(b) and 8(c) needs to be clarified. The phrase "by an organization which has been authorized by HOKLAS to endorse the certificate or test report in the name of HOKLAS" does not fit with the terminology used in the rest of the document. Perhaps this phrase should be "by an organization which has been accredited by HOKLAS for the tests involved" for 8(b) and "by an organization which has been accredited by an accreditation body for the tests involved" for 8(c).
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Schedule 1
Schedule 1, 2(c)
Schedule 1, 2(e)
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Clipsal Asia Limited
(Appendix 4)
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In the General Conditions of the Schedule 1 - Essential Safety Requirements For Electrical Products, there is no specific safety standard of which the manufacturers and/or the suppliers of electrical products shall refer to. We recommend that compliance with the International Electrotechnical Commission (IEC) Standard or equivalent should be employed extensively throughout the paper. As the trend indicates, IEC Standard will be the ultimate and the only standard recognised all over the world in the future. At the moment, most of the industrial developed countries accept both the IEC Standard and the standards of their own countries e.g. U.K., Germany, France, P.R.C., Australia etc. simultaneously. In Hong Kong, for instance, most of the electrical consulting engineers even Hong Kong Housing Authority accept both the IEC Standard and the British Standard for electrical installation products in new building projects. In the meantime, the IEC is also undergoing harmonisation programme with the standards of the rest (of the) countries for example the South African Bureau of Standards (SABS). Increasing number of such harmonisation programme will be realised in the near future. By adapting to the IEC standards, we could set up a base line for the least electrical safety standard and the compatibility of electrical safety for products intended (for) use in Hong Kong. This would also save a lot of resources in assessment of a standard not yet recognised by the Director of EMSD and greatly reduce the foreseeable disputes in safety compliance in the future.
Clause 2(c) of the Schedule 1 reads persons, animals and property are adequately protected against any non-electrical danger which might be caused by the electrical product. In our opinion, this clause should be deleted because "any non-electrical danger" could mean "every possible danger". It will be absolutely absurd that a manufacturer of electrical product may be accused for non-compliance with the regulation if someone drops the electrical product onto another person causing physical injury or other harm.
For the same token, the word "any" should be deleted in all the clauses stipulated. Protection against hazards which may be caused by external influences on an electrical product and "under normal operation conditions" should entail the said clauses.
Clause 2(e) of the schedule 1 reads the insulation is suitable for all foreseeable conditions. Again, this sentence is so arbitrary that "all foreseeable conditions" will include for instance cutting by knife literally. We suggest to change the sentence to "the insulation is suitable for preventing electrocution (or electrical shock) under normal operation conditions."
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Schedule 2 Item 1
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Vocational Training Council
(Appendix 17)
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For 13A fused plug available on the market, a 13A fuse is usually provided. The 13A fuse may not possibly protect an appliance consuming less than a few ampere. A notice may be necessary to warn consumers that the 13A fuse may need to be replaced with a fuse of rating appropriate for the equipment served. |
