how to successfully approach manufacturer for information

[s harris]

Hi

I wondered if I could ask for advice on how to succeed in getting some basic technical information from the manufacturer of consumer electrical equipment. Does anyone have any pointers, or thoughts please?

The item is a coffee machine which I recently had to test but I couldn't find any earthed metallic points on the body to carry out an earth continuity test. So I took a picture of the label, attached it and emailed the manufacturer as follows:

Hi

I tried PAT testing this coffee maker earlier today but could not find any earthed metallic conductive part on the body upon which to measure earth
continuity. I tried all visible metallic parts and accessible screws. Please could you advise where on the body can be accessed using a probe for an earth continuity test?

Thank you

I received an initial response asking for proof of purchase and further photographs, which I could not provide, to which I responded:

Thank you for your reply.

I can provide you with a photo of the close-up of the label which I took at the premises on Friday.

However I can't take the photos you would like me to provide right now because I did not buy the product and I am no longer in the same location
as the product.

I'm asking the question as it was my job to do portable appliance testing on items of equipment at that premises and I couldn't locate an earthed
point anywhere on the model to adequately carry out the test for earth continuity.

As I hope to revisit the premises in the future to carry out the electrical safety test for earth continuity, I thought I'd ask you where there is an
accessible earthed point on the model.

Please could you let me know where the testing point is on the model (Coffee maker ******)?

Many thanks

Here is the reply:

This is commercially sensitive and we would not share that level of technical specifications with customers. It does meet all food safety standards as per British and European Regulations.

I sincerely apologise for the inconvenience caused and I'm sorry I could not offer a more favourable reply.

If I can be of further assistance, please reply to this email directly.

How can I respond in such a way to get the information I want?

Many thanks, any advice is appreciated.

 

[DPG]

Is it definitely class 1?

 

[s harris]

Is it definitely class 1?

Hi DPG,

Thanks for replying.

I'd have to say yes as there's no double insulation class II symbol anywhere on the (nearly new) machine, even though it looks very, very plastic. Rather thick (unmarked) lead and (annoyingly) a moulded plug.

The instruction manual contains this section, though there is no mention in the specification of Class of equipment.

 

[DPG]

Is it a reputable make? I'm surprised it doesn't state class 1 or 2 in the manual.

I'd reply to them stating that equipment like this needs to be regularly tested to comply with ISITEE legislation, and that they are duty bound to give sufficient information to enable this.

 

[westward10]

What is the make and model number. A lot of these of these domestic type machines assuming that is what it is have metal over the plastic casing which requires no earth.

 

[DPG]

What is the make and model number. A lot of these of these domestic type machines assuming that is what it is have metal over the plastic casing which requires no earth.

Should be stated as class II then though.

Is it CE marked ?

 

[s harris]

Is it a reputable make? I'm surprised it doesn't state class 1 or 2 in the manual.

I'd reply to them stating that equipment like this needs to be regularly tested to comply with ISITEE legislation, and that they are duty bound to give sufficient information to enable this.

Thank you DPG. I didn't know manufacturers of electrical equipment were duty bound to enable this. Do you happen to know which instrument of legislation applies to manufacturers?
...I'm pretty sure all of the below apply to employers and employees:
The Health & Safety at Work Act 1974,
The Management of Health & Safety at Work Regulations 1999,
The Electricity at Work Regulations 1989,
The Workplace (Health, Safety and Welfare) Regulations 1992
The Provision and Use of Work Equipment Regulations 1998.

 

[DPG]

Thank you DPG. I didn't know manufacturers of electrical equipment were duty bound to enable this. Do you happen to know which instrument of legislation applies to manufacturers?
...I'm pretty sure none of the below apply to employers and employees:
The Health & Safety at Work Act 1974,
The Management of Health & Safety at Work Regulations 1999,
The Electricity at Work Regulations 1989,
The Workplace (Health, Safety and Welfare) Regulations 1992
The Provision and Use of Work Equipment Regulations 1998.

I don't know of any specific regulation, but how can their equipment be tested for safety if they won't give basic information out?

 

[s harris]

 

[s harris]

Only metal parts accessible are: faceplate / handles / knobs / drip feed nozzle / grille (mounted on plastic drip tray).
Four screws are underneath. Two have no connection to earth. The other two were set so deep inside the probe will not reach (not even with a Megger super long thin probe).

 

[westward10]

It is highly unlikely those parts need to be earthed they a mostly 'bling'. You can probably see on the cord sheath if it is two or three core most are three but the earth is probably utilised internally. It is Class I or Class I/II.

 

[s harris]

I don't know of any specific regulation, but how can their equipment be tested for safety if they won't give basic information out?

Ah, sorry, I meant to say 'ALL of the below apply to employers and employees', not 'none'. I would like to quote legislation to support my request, but I don't think any of the above legislation applies to manufacturers of electrical equipment, just to employers and employees using that equipment at work.

 

[s harris]

It is highly unlikely those parts need to be earthed they a mostly 'bling'. You can probably see on the cord sheath if it is two or three core most are three but the earth is probably utilised internally. It is Class I or Class I/II.

Thank you Westward10.
The cord is quite thick. Sorry I don't know what 'Class I/II' means.

 

[DPG]

Thank you Westward10.
The cord is quite thick. Sorry I don't know what 'Class I/II' means.

Surely that's a fundamental thing to be aware of if you are doing PAT/ ISITEE testing?

Class II is double insulated, or a single layer of reinforced insulation.

Edit: sorry, have just realised what you meant.

 

[westward10]

Thank you Westward10.
The cord is quite thick. Sorry I don't know what 'Class I/II' means.

Sorry have probably confused a bit. What you have is a Class I appliance however all the earthed components are encased in what is essentially a Class II enclosure but realistically the appliance is Class I so I called it Class I/II but it is Class I.

 

[DPG]

I agree. It has to be a class I, since there is no class II identifier either on the appliance or in the manual

 

[snowhead]

If it's not marked it must be Class 1.

Skip to 13 min onwards, on this John Ward video, he explains why the outer metal surfaces don't need to be earthed.

 

[pirate]

I concur with @westward10 on this. it's a hybrid Class I/II. There are no metal parts on the body, which is not uncommon these days. I would state it as Class I but also state it as tested as Class II due to no accessible metal parts.
If there's no metal, the shock risk is somewhat low...

 

[Petej999]

I concur with @westward10 on this. it's a hybrid Class I/II. There are no metal parts on the body, which is not uncommon these days. I would state it as Class I but also state it as tested as Class II due to no accessible metal parts.
If there's no metal, the shock risk is somewhat low...

Just ask politely explaining your details and problems, most suppliers will help

 

[loz2754]

The first line in the manual as shown in the photo above says "this appliance must be earthed".
Therefore it is Class I.

As there appear to be no exposed conductive parts, as indicated by the OP when conducting the test, how would we know if the appliance earth connection has failed? Or that one or more of the metallic parts that are accessible should, in fact, give a continuity reading?

Very poor on the part of the manufacturer if you ask me!

 

[DPG]

The first line in the manual as shown in the photo above says "this appliance must be earthed".
Therefore it is Class I.

As there appear to be no exposed conductive parts, as indicated by the OP when conducting the test, how would we know if the appliance earth connection has failed? Or that one or more of the metallic parts that are accessible should, in fact, give a continuity reading?

Very poor on the part of the manufacturer if you ask me!

Seems to be a more common thing these days as well.

Worth googling the 'Functional earth' logo as well

 

[brianmoooore]

Is the heater element accessible with a probe? This is likely to be metal, and likely to be earthed.

 

[Lucien Nunes]

I was thinking along the same lines; this presumably has an earth because the boiler is class I. If the water feed pipe to the group head is metallic then by removing the portafilter and probing up inside the group head you might get lucky. OTOH if it is connected by a length of silicone tubing you're snookered.

As far as Breville's response goes, it sounds like the work of the customer services people, whereas if they have a technical department they might give a better answer. I would address any enquiry direct to technical and request their recommended procedure for ISITEE in accordance with the current ACoP.

If it turns out they only sell products branded for them by an independent maker then you might find the technical department is in China. Good luck.

 

[s harris]

Sorry have probably confused a bit. What you have is a Class I appliance however all the earthed components are encased in what is essentially a Class II enclosure but realistically the appliance is Class I so I called it Class I/II but it is Class I.

Ah, I see. Thanks for the clarification!

 

[s harris]

I was thinking along the same lines; this presumably has an earth because the boiler is class I. If the water feed pipe to the group head is metallic then by removing the portafilter and probing up inside the group head you might get lucky. OTOH if it is connected by a length of silicone tubing you're snookered.

As far as Breville's response goes, it sounds like the work of the customer services people, whereas if they have a technical department they might give a better answer. I would address any enquiry direct to technical and request their recommended procedure for ISITEE in accordance with the current ACoP.

If it turns out they only sell products branded for them by an independent maker then you might find the technical department is in China. Good luck.

Thank you for your kind and detailed reply Lucien Nunes.
Thanks to your post, I googled 'portafilter' and 'group head' - which were new to me - next time I'm at the premises or in a similar situation I'll know to go for the water feed pipe!

 

[s harris]

Thanks to all who replied to this thread. Much obliged for the all the input.

I'm still hoping for a result from Breville and will update if it comes.

Meanwhile The CE Marking Association were very helpful with identifying some relevant legislation.


Article 6(7) of the Low Voltage Directive 2014/35/EU :


Section 9 of The Electrical Equipment (Safety) Regulations 2016:


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Thank you for your prompt and polite reply to my query.

However, I am not happy with two aspects of the response given:

1. 'This is commercially sensitive and we would not share that level of technical specifications with customers.'
- I am not asking for commercially sensitive information. I am asking for basic information on maintaining the electrical safety of your consumer equipment in a low-risk environment. I believe Breville are obliged to provide this type of technical specification to the end user.

2. 'It does meet all food safety standards as per British and European Regulations.'
- This issue is not to do with food safety standards, it is to do with electrical safety standards. The relevant instrument for compliance here is The Electrical Equipment (Safety) Regulations 2016, which places upon the manufacturer an obligation to provide safety information for marketed
equipment.

I did however feel you answered me very politely and appreciate you must genuinely feel unable to give me the information I asked for.

Just to reiterate, I asked you where on the VCF145 I can locate an exposed conductive part for carrying out the protective conductor continuity test as part of the portable appliance testing ('PAT testing') procedure.

If you still feel unable to provide me with this information, please could you kindly direct my query to someone in your technical department?

Many thanks for your kind help
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Thank you for your reply.

Sadly, we can not forward your inquiry to our technical department and we are unable to provide you any technical information.

I sincerely apologise for the inconvenience caused and I'm sorry I could not offer a more favourable reply.

If I can be of further assistance, please reply to this email directly.

Thank you
----------------------------------------------------------------------------

Thank you for your courteous reply.

However it's disappointing to hear you cannot give out technical information or forward my query to your technical department.

Would you be able to kindly give me the contact details for your technical department so that I can email them myself?

Many thanks
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Thank you for your reply.

Unfortunately, we can not share with you any contact details of our technical department.

Please note we can only forward PAT results to our technical team.

I sincerely apologise for the inconvenience caused and I'm sorry I could not offer a more favourable reply.

Thank you
----------------------------------------------------------------------------

Thank you for your polite reply.

That is frustrating news but I understand you are only doing as instructed.

Just to reiterate, I am asking for some basic safety information as an end user of one of your consumer products. I believe that providing such information is an obligation of the manufacturer (you) under the Low Voltage Directive 2014/35/EU and The Electrical Equipment (Safety)
Regulations 2016.

Please could you kindly help me make a formal complaint? I cannot find any information online regarding a complaints procedure, apart from contacting Customer Services.

Many thanks
----------------------------------------------------------------------------
Thank you for your response.

Kindly accept our apologies for any inconvenience caused.

Please reply to this email with your formal complaint.

Thank you
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Thank you for your kind reply. Please will you forward this formal complaint to the relevant party?

Dear sir or madam,

As an end-user I would like to know where I can find an exposed-conductive-part on the Class I VCF145 coffee maker for portable appliance testing. This is not at all obvious upon visual inspection and it is not indicated in the instruction manual. Without this essential safety
information I cannot carry out the protective conductor continuity test on the item to confirm it is safe for continued use (PAT).

Your consumer service representative has informed me that you do not give out this type of information to customers, as it is commercially sensitive. They have also informed me that they cannot redirect my query to, or provide contact details for your technical team.

My main complaint is that you should not be withholding this type of essential safety information at all from customers or end-users. As basic safety information for a Class I item of equipment where the identification of an exposed-conductive-part is not straightforward, its location should really be illustrated plainly in the instruction manual.

As I see it you have marketed the VCF145 as a Class I item of equipment, then refused to support the end-user on how to maintain it safely, which is not compliant with current legislation. As a manufacturer of an item of electrical equipment bearing the CE Mark you are duty bound to provide the customer and end-user with instructions and safety information in compliance with Article 6(7) of the Low Voltage Directive 2014/35/EU and Section 9 of The Electrical Equipment (Safety) Regulations 2016.

It is bewildering that you have instructed your customer service representatives to withhold this type of safety information on the basis that it is commercially sensitive. Clearly this cannot be an item of commercially sensitive information. It is essential for ongoing safe maintenance of your equipment.

Finally I am unimpressed by a system that discourages direct communication with a technical team on a technical matter. I can only hope for a positive result having made this a formal complaint, but cannot shake the feeling my message is going to circulate in a loop with your consumer services
representative, who for all his politeness must be getting pretty fed up with me by now.

Thank you for your attention
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Thank you for your response and your time to explain the reason of contact.

Your email has been passed over to the technical team. If they will find it of any interest they will reach out directly. On our side, this is as far as we can help.

Have a good day.

Thank you
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[s harris]

Sorry to bombard thread but thanks to DG for the remark about the CE mark, which led me to find the legislation I wanted.

 

[DPG]

Sorry to bombard thread but thanks to DG for the remark about the CE mark, which led me to find the legislation I wanted.

Keep us posted. As you say, it's dissappointing when you get this sort of communication failure, especially from a company which really should know better.