ulstandards.ul.com€¦  · web viewthe word “function” is not to be linked to “functional...

24
61(Bled/AG28)02g.Rev.1.2 May 2019 INTERNATIONAL ELECTROTECHNICAL COMMISSION TECHNICAL COMMITTEE NO. 61 SAFETY OF HOUSEHOLD AND SIMILAR ELECTRICAL APPLIANCES Report from AG 28 ---------------------------------------------------- Since the last meeting of TC 61, TC 61/AG28, responded to following enquiries: Standard Clause(s) Referenc e 60335-1 19.11.4 – 19.13 BR 01 60335-1 19.5 UK 01 60335-1 22.44 CN 02 60335-1 22.44 CN 03 60335-1 22.56 CN 01 60335-1 25.2 CN 06 60335-2-9 1 CN 05 60335-2-14 20.2 FR 01 60335-2-23 10 HK 01 60335-2-30 20.101 CN 04 60335-2-31 30.101 IR 01 In red the enquiries added with reference to previous version These Enquiries and the draft responses are listed in Annex in the order of standards/Country. You are requested to review the responses and either confirm or comment on them for final discussion and decision of the TC on 7 th June. ®

Upload: others

Post on 01-Sep-2019

4 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

61(Bled/AG28)02g.Rev.1.2

May 2019

INTERNATIONAL ELECTROTECHNICAL COMMISSION

TECHNICAL COMMITTEE NO. 61SAFETY OF HOUSEHOLD AND SIMILAR ELECTRICAL APPLIANCES

Report from AG 28

----------------------------------------------------

Since the last meeting of TC 61, TC 61/AG28, responded to following enquiries:

Standard Clause(s) Reference

60335-1 19.11.4 – 19.13 BR 01

60335-1 19.5 UK 01

60335-1 22.44 CN 02

60335-1 22.44 CN 03

60335-1 22.56 CN 01

60335-1 25.2 CN 06

60335-2-9 1 CN 05

60335-2-14 20.2 FR 01

60335-2-23 10 HK 01

60335-2-30 20.101 CN 04

60335-2-31 30.101 IR 01

In red the enquiries added with reference to previous version

These Enquiries and the draft responses are listed in Annex in the order of standards/Country.

You are requested to review the responses and either confirm or comment on them for final discussion and decision of the TC on 7th June.

The following shall be noted.

The answers provided are for the standards as written. The use made of these answers by the originators of the inquiry, and by others, is their own responsibility. No guarantee can be given that subsequent amendments of the standards will support the answers.

®

Page 2: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

BR-01_(Bled) 2019.02.01 AG28

Standard Subclause(s) Keywords

IEC 60335-1 Ed5.2 19.11.4 – 19.13 Dangerous mulfunction

Question

Considering that the test provided in item 19.11.4 of the IEC 60335-1 standard provides for its realization for devices that have a device with a stand-by or stand-by device:

Considering that the criterion of approval established in item 19.13 of the standard IEC 60335-1 for the tests carried out in item 19.11.4 establishes that:

Considering the definition of dangerous malfunction presented in item 3.1.11 of the standard IEC60335-1 below:

Considering the provisions of item 5.3 of IEC 60335-1 that there being evidence in the construction of the apparatus that certain tests may not be applicable depending on the evaluation performed:

We understand that the test referred to in item 19.11.4 is not necessary on devices that have electronic shutdown or stand-by mode since in the evaluation of the product in its constructive way there is no possibility of a dangerous malfunction. A document which also serves as a basis for the above conclusion is the "Decision Sheet OSM / HA 401" issued by ETICS (European System of Tests, Inspections and Certifications) where it lists all IEC 60335 series appliance standards and the applicability or otherwise of the condition of possibility of operation insecure or not.

Considering that there are conflicting interpretations between certification bodies as to whether or not the test of item 19.11.4 of IEC 60335 is to be performed even after analysis and verification, we request a consultation with the IEC in order to ratify our interpretation, so that we can later standardize the criterion among all.

Proposed MT23 answer:

2

Page 3: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Firstly OSM / HA 401 has no relevance in IEC; furthermore it was developed on basis of test house engineers and not on basis of the European Committee of TC61. It was discussed 2008 and take not into account the status of standards valid today.

Moreover it is not anymore listed on the IECEE Webside under OSM decision sheets.

Secondly the note in 19.13 was added as a kind of guidance to help manufacturer to get a feeling in the evaluation of dangerous mail function using engineering procedures to decide acc. to 5.3 which tests are necessary or not.

The possibility of dangerous malfunction shall be evaluated for the EUT on a case-by-case basis and not using a general table for the decision to decide whether or not the test of item 19.11.4 of IEC 60335 needs to be performed or not.

TC 61 Decision

3

Page 4: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

UK-01 (Bled) 2019.01.07 AG28

Standard Subclause(s) Keywords

IEC 60335-1:2010+AMD1:2013+AMD2:2016

19.5 Tubular sheathed heating element - embedded

Question

Ferro Techniek make heating elements using a thick film process. See http://www.ferrotechniek.com/thick_film_heaters/technology.aspx The construction is shown below. However the terminology used in the labelling is not that of the standards. The word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation.

                               

As you will be aware, Clause 19.5 requires Class 01 and Class 1 appliances with tubular sheathed or embedded elements to be tested with one end of the element connected to the sheath. My understanding is that this test simulates the failure of the insulation effectively allowing the current to bypass any control in series with the element at that end of the element.Of course reason this is performed with sheathed or embedded elements is the inability of the majority of heating element manufacturers to seal elements using magnesium oxide as the insulator sufficiently well to stop the ingress of moisture and the subsequent deterioration of the insulating properties of the magnesium oxide.With a thick film heating element of the type made by Ferro Techniek the insulation is not magnesium oxide. Instead the insulation between the heating track and the steel substrate (the second layer from the bottom, coloured ) is glass. This is virtually impervious to humidity.

4

Page 5: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

The manufacturing process of this heating element is as follows;1. A layer of glass enamel is sprayed onto the specially prepared surface of the steel. The glass is in the form of a frit, small particles of glass.2. The layer is dried and then fired . This firing process fuses the glass particles together and to the steel to form a homogeneous layer. This is referred to as the dielectric layer.3. The heater track, in the form of a paste is screen printed onto the dielectric layer. The paste is a suspension of silver and other metal particles in a binder.4. The heater track is then dried and fired.5. Steps 3 and 4 can be repeated to apply low resistance connection points if desired. These are not shown on the diagram above. At this point the heater will function. Provided the creepage and clearance rules are observed the heater could in theory be used. However the heater track and connection points are rather delicate so a further layer of insulation is applied.6. A cover layer is added by screen printing a layer of glass paste. There are holes in the cover layer to allow connections to be made.7. The cover layer is then dried and fired. The firing process fuses the glass particles on the cover layer and fuses the cover layer to the heater track and to the dielectric layer between the heater track. The result is that all the layers are fused together and to the steel substrate creating an assembly which is impervious to moisture.It certainly does not react to humid conditions in the way that magnesium oxide does.If the top layer of insulation is omitted the heating element could not be described as an embedded element. An element without the top layer of insulation would pass the humidity tests of 60335 and in fact would pass much more severe humid conditions without failure of the insulation. If you could make a tubular sheathed element or an embedded element where the resistor wire was exposed the insulation would quickly absorb moisture leading to a failure of the insulation. A thick film element should not be categorised as an embedded element. For this reason we believe that Clause 19.5 should not be performed on appliances with thick film elements. If 19.5 has to be performed an extra thermal cut-out or thermal fuse in required. This adds unnecessarily to the cost of the appliance.

AG 28 Answer

The construction of the heating element shown in the sketch provided and described by the enquirer is not considered to qualify it as an embedded heating element.

In fact the construction process is such to allow the main heater track, with the function of heat generation, to be an integral part of the heating element itself.

This answer only refers to the product and the construction indicated by the enquirer.

TC 61 Decision

5

Page 6: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

CN-02_(Bled) 2019.3.16 TC61/AG28

Standard Subclause(s) Keywords

IEC 60335-1:2016 Ed5.2 22.44 Robot with air cleaning, vacuum cleaner function

Question

Multi-function Robot

Vacuum cleaner unit

The smart robot with multi-function, such as HiFi, game projector, VOD, DVD player, phone projector, includes air cleaner in main body part and automatic battery-powered vacuum cleaners(seperate unit). IEC 60335-2-2 and IEC 60335-2-65 standards are applicable.Does the robot comply with clause 22.44 of IEC 60335-1:2016 Ed5.2?Opinion 1: A robot is robot, not representing animals, characters, persons or scale model, OK.Opinion 2: the robot looks like a “human being”, fail.

AG 28 Answer

The multi-function nature of the product, which can be re-imagined as an entertainment system that also vacuums and cleans the air, does not exempt the appliance to meet the requirements of 22.44 and this cannot be waived or superseded by the other end application requirements (e.g. by IEC 62368-1).

As consequence and although it is realised that this type of robotic appliances performing also household functions is getting more and more common, this appliance does not comply with the requirements of 22.44 as it is written.

This being said, it is needed that IEC TC 61/WG44 duly considers the more and more diffused service robots which have household functions (e.g. cleaning, air purifying) and other additional functions (e.g. entertainment, game playing), evaluates how this can match with the requirements in the IEC 60335 series of standards series and if there is a need to define specific additional requirements (e.g. revision of 22.44, functional safety, remote operation, etc.) for this type of appliances that are already quite diffused and will be more and more in

6

Page 7: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

future.

TC 61 Decision

7

Page 8: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

CN-03_(Bled) 2019.4.24 TC61/AG28

Standard Subclause(s) Keywords

IEC 60335-1:2016 Ed5.2 22.44 Toy – enclosure – shaped - decorated

Question

IEC 60335-1:2016 Ed5.2 states,22.44 Appliances shall not have an enclosure that is shaped or decorated like a toy.NOTE Examples of such enclosures are those representing animals, characters, persons or scale models.Compliance is checked by inspection.CTL 1081decision sheet reads,5 – Toaster (animals/characters partly simulated enclosures): Does not comply with sub-clause

7 – Hair drier (animals/characters printed enclosures): In compliance with sub-clause

We are wondering if we could ask IEC/TC61 to clarify whether the enclsoure of electrical appliance partly representing an animal fufil clause 22.44.Example1, a kettle with a “horse” device to link the handle and the lid, which prevents the lid dropping from the container.

8

Page 9: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Similar example see example 2.Example2 an appliance with a “cactus tree”

AG 28 Answer

The appliance in Example 1: kettle with a “horse” device to link the handle and the lid complies with 22.44 as the horse device is not part of the enclosure.The appliance in example 2: humidifier which has a part of the enclosure ressembling to a cactus tree does not comply.

TC 61 Decision

9

Page 10: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

CN-01_(Bled) 2019.01.17 AG28

Standard Subclause(s) Keywords

IEC 60335-1 Ed5.2 22.56 wireless charging teeth brush2 hand-held unit1 wireless charging stand

Question

Does two wireless charging teeth brush hand-held units with only one wireless charging stand in a sales package box comply with clause 22.56 of IEC 60335-1 Ed5.2?

Opinion 1: it is accepted, one family uses one package box of brush, saving resource to protect the earth.Opinion2: one hand-held unit should be provided with one charging stand. Now 2 hand-held units with only 1 charging stand, it is not accepted.Which opinion is correct? AG 28 Answer

The particular situation described by the enquirer, where two teeth brushes are sold in the same package with one charging stand, is considered to meet the requirements in 22.56.

TC 61 Decision

10

Page 11: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

CN-06_(Bled) 2019.5. 31 TC61/AG28

Standard Subclause(s) Keywords

IEC 60335-1 Ed5.2 25.2 12Vd.c.muliple supply/ supply mains

Question

The part 1 standard reads,25.2 Appliances, other than stationary appliances for multiple supply, shall not be provided with more than one means of connection to the supply mains. Stationary appliances for multiple supply may be provided with more than one means of connection provided that the relevant circuits are adequately insulated from each other. We are wondering if we could ask IEC/TC61 to clarify whether 12Vd.c. battery on vehicle or portable 12Vd.c. rechargeable battery box is one kind of “muliple supply/ supply mains”For example, a portable electric fan with two alternative inputs, Input 1: 220Va.c. (supply main drives the fan and/or charges the bult-in battery)Input 2: 12Vd.c. (12Vd.c. baterry on vehicle or portable 12Vd.c. rechargeable battery box drives the fan)

Opinion 1: 12Vd.c. is one kind of “muliple supply/ supply mains”, clause 25.2 fail.Opinion 2: 12Vd.c. is NOT one kind of “muliple supply/ supply mains”, clause 25.2 pass.

Which opinion is correct?

AG 28 Answer

‘Supply mains’ or ‘mains supply’ is not defined in the IEC 60335 standards, but in according to electropedia, the definition of mains frequency (there is no definitions of supply mains) is: frequency of the AC electric power system supplying the electroheating power network and in some dictionaries it is defined as: mains supply - electricity, water, or gas supplied to a building through wires or pipes

In addition if one reads the overall content of IEC 60335-1 it may be understood that supply mains refers to the power supply network.

In that respect a 12 V dc is another supply but it is not considered a mains supply or supply mains.

From the product in the picture submitted by the enquirer it is considered that there is only

11

Page 12: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

one mains supply.

It shall be considered, even if not especially likely, the potential hazard if the appliance is supplied at both mains and battery voltage. The appliance photo doesn’t show a means to prevent simultaneous connection nor does it appear to have a voltage selector switch.

In addition 22.26 shall also be carefully considered.

TC 61 Decision

12

Page 13: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

CN-05_(Bled) 2019.5.29 TC61/AG28

Standard Subclause(s) Keywords

IEC 60335-2-9:2019 1 Portable steam oven

Question

Which standard is applicable to portable steam oven, IEC 60335-2-9 or IEC 60335-2-15?

Note: only steam cooking function without any other fuction, 5 kg, 20 litreFigure portable steam oven

Opinion1: stationary steam ovens fall in the scope of IEC 60335-2-6, so portable steam oven is in the scope of IEC 60335-2-9.Opinion2: IEC 60335-2-15 liquid heater/ steam cooker is more suitable then IEC 60335-2-9 portable oven.Which opinion is correct?AG 28 Answer

The appliance falls under 60335-2-9.

For the verification of the steaming function and according to the sentence in the fourth paragraph of the introduction to IEC 60335-2-9:2019:

If an appliance within the scope of this standard also incorporates functions that are covered by another part 2 of IEC 60335, the relevant part 2 is applied to each function separately, as far as is reasonable. If applicable, the influence of one function on the other is taken into account.

also Part 2-6 for the steaming function and Part 2-15 for the heating of liquids function should be taken into consideration.

TC 61 Decision

13

Page 14: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

FR-01(Bled) 2019.06.06 AG 28

Standard Subclause(s) Keywords

IEC 60335-2-14:2016/A1:2019

20.2

Question

The FR NC has a question about the IEC 60335-2-14 ed 6.1 clause 20.2 that says : “The test probe is not applied to feed openings having a throat with the following dimensions: »Different shapes of throat are possible for instance “straight cylinder”, funnel with a “V shape”, oval, conical…

Example of “V shape”

Example of “straight cylinder”The opinion of FR NC is that the term “throat” covers every kind of shape. Does IEC TC61 confirm ?

Proposed answer From MT46

Yes. The term "throat" is used in relation to the feed opening intentionally to prevent specifying a particular shape. Furthermore, the standard is clear about the criteria of the throat of feed opening, and specifies only the three dimensions in the bulleted items. If it was the intend to allow only a specific throat shape, for example a funnel shape (wide at the top and narrow on the bottom), more dimensions and instructions would have been specified.

TC 61 Decision

14

Page 15: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

15

Page 16: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

HK-01 (Bled) 2018.12.05 AG28

Standard Subclause(s) Keywords

IEC 60335-2-23:2016 10 Power input deviation - normal use

Question

The product has equipped an intelligent circuit and it is capable to monitor flow rate and adjust its performance to ensure user satisfaction.  The product consists of features with Hair-Curler, Hair-Dryer and Hair-Brusher while different accessories applies:

The issue is that we are in discussion with Certification Body upon CB Certification about the rated power to be marked on product.The product is rated at 1300W and the power deviation allowed in standard is +5%/-10%.  The standard IEC 60335-2-23 and IEC 60335-1 has not given clear instruction in Cl.10 for Input Power Measurement whether accessories and given reference in Cl.5.9 as generic guideline that  accessories giving most unfavourable result shall be used:

An observation has been found that the power consumption would be reduced when different accessories being applied.  The product measured with 1300W (+0%) with no accessory applied and measured 1070W (-17.7%) with attachment applied. The discussion with Certification Body involves 2 options:

1. Mark 1300W on product, due to the fact that the product itself generates 1300W maximum with no accessory applied. There exists scenario that the product can be switched on with no accessories applies and foreseeable mis-used.

2. Mark 1070W on product, due to the reason that the product measured 1070W in actual use with accessories applied.

We are in opinion of taking the former approach in view of worst case scenario, as the product may be tested during surveillance in market and the test house may also consider the product being tested with no accessory applied in future.  In addition, taking the latter approach is relatively severe in view of product safety as marked with 1070W but measured 1300W which is much higher power in actual.Appreciate an advice from TC 61 so that we could have an aligned decision to handle this special product.As shown in the instructions for use are enclosed, the appliance can be operated without accessory attached, but this is not the intended use as the operating condition with no accessory is not mentioned in user manual at all. Just the conditions with accessories were shown there.

AG 28 Answer

16

Page 17: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Based on 3.1.9 and 5.9 and taking into consideration the specific mode of the operation of the appliance for which the question is raised and which are given in the instruction for use, it is considered that the operation of the appliance without accessories is not meant to be normal use, unless this product is intended to be used as a hairdryer when no accessory is fitted.

Therefore the input shall be measured with the accessory giving the highest input value (most unfavorable result, as defined in 5.9, as far Clause 10 is concerned).

This answer refers to this specific type of product.

TC 61 Decision

17

Page 18: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

CN-04_(Bled) 2019.05.13 TC61/AG28

Standard Subclause(s) Keywords

IEC 60335-2-30:2004 Ed4.1 30.101 Room heater - LED lamp - Lamp diffuser

Question

We are wondering if we could ask IEC/TC61 to clarify whether the lamp diffuser of a multi-function room heater on bathroom ceiling is a part of “enclosure”, and applicable to clause 30.101 needle-flame test.

Figure multi-function room heater on bathroom ceiling

Figure LED lamp module and S.E.L.V driver

18

Page 19: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Figure LED-Reflecive sheet – Light guide plate - DiffuserNote: Multi-function room heater with ventilation fan, fan heater and LED lamp functionLED lamp module supplied by S.E.L.V driver.Lights come from the LED diodes, go through Light Guide Plate and Diffuser.3 blows on the LED diffuser position according to clause 21.1, no damage that impair compliance with standard, especially 8.1 and 29.Opinion 1: the lamp diffuser of lamp unit is not enclsure of room heater, it must be transparent, so needle-flame test for room heater is not applicale.Opinion 2: the lamp diffuser of lamp unit is a part of enclsure of room heater, so needle-flame test for room heater is applicale.Which opinion is correct?AG 28 Answer

The tests of 30.101 is applicable to lamp diffuser

TC 61 Decision

19

Page 20: ulstandards.ul.com€¦  · Web viewThe word “function” is not to be linked to “functional insulation”. The green layer is actually basic insulation. The green layer is actually

Annex to 61(Bled/AG28)02g

Reference Date Provided to

IR-01 (Bled) 2019.03.09 AG28

Standard Subclause(s) Keywords

IEC 60335-2-31:2012+AMD1:2016+AMD2:2018

30.101 Droplets – Needle flame -

Question

We have a range hood, (regard attachment) In accordance with sub clause 30.101 IEC 60335-2-31

“ Appliances shall not incorporate combustible material liable to appreciably propagate a fire originating underneath the hood.

Compliance is checked as follows. Filters of non-metallic material intended for the absorption of grease shall meet the requirements specified in ISO 9772 for category HBF material, except that the thickness of the specimen is that of the filter. It may be necessary to support the specimen during the test.

Lamp diffusers and external air-guides having a total mass not exceeding 0,35 kg is subjected to the glow-wire test of IEC 60695-2-11 at a temperature of 550 ̊C. The glow-wire test is not carried out on parts of material classified at least HB40 according to IEC 60695-11-10, provided that the test sample was no thicker than the relevant part.

Other accessible parts of the enclosure are subjected to the needle-flame test of Annex E.Internal air-ducts and parts within them, such as fans, are subjected to the needle-flame test of Annex E, droplets of material being ignored.Grease filters are not subjected to this test. “

Does the term " droplets of material being ignored " mean that burning or melting particles in the test sample that fall on the specified layer or the standard layer being ignored?

AG 28 Answer

When internal air-ducts and parts within them, such as fans of products covered by IEC 60335-2-31:2012+AMD1:2016+AMD2:2018, are subjected to the needle-flame test of Annex E, droplets of material are ignored.

To be noted that this is a relaxation only for internal air ducts and parts within them, such as fans and odour extraction filters.

TC 61 Decision

20