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61(Busan/FINC)31For IEC use only

October 2018

INTERNATIONAL ELECTROTECHNICAL COMMISSION

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

Compilation of comments on 61/5700/DC: Proposal of the Finland National Committee for an amendment to IEC 60335-2-53: Particular requirements for sauna heating appliances and infrared cabins.

Note: This document will be discussed during the TC 61 Plenary meeting in Busan, Republic of Korea, 21-27 October 2018. After the meeting, a revised INF document will be circulated with Observations of the Secretariat included.

Copyright © 2023 International Electrotechnical Commission, IEC . All rights reserved. It is permitted to download this electronic file, to make a copy and to print out the content for the sole purpose of preparing National Committee positions. You may not copy or "mirror" the file or printed version of the document, or any part of it, for any other purpose without permission in writing from IEC.

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61/5718/INF

Annex A

Report of Comments on 61/5700/DCCirculation Date: 2018-06-22 Closing Date: 2018-08-17

Proposal of the Finland National Committee for an amendment to IEC 60335-2-53: Particular requirements for sauna heating appliances and infrared cabins

Country Status Comments ReceivedAlbania PArgentina OAustralia P N 2018-08-10Austria P Y 2018-08-14Belarus O N 2018-08-17Belgium P N 2018-08-17Brazil O N 2018-08-17Bulgaria OCanada P Y 2018-07-30China P N 2018-08-14Czech Republic P N 2018-08-10Denmark P N 2018-08-17Egypt P N 2018-08-16Finland P N 2018-08-16France P N 2018-08-07Germany P Y 2018-08-13Greece PHungary P N 2018-08-15India P N 2018-08-13Indonesia P N 2018-08-08Iran P N 2018-08-15Ireland P N 2018-06-28Israel P N 2018-08-17Italy P N 2018-07-30Japan P N 2018-08-10Korea, Republic of P N 2018-08-17Kuwait OMalaysia P N 2018-07-30Mexico P Y 2018-08-17Netherlands P N 2018-08-09New Zealand P Y 2018-08-08Norway P N 2018-08-13Pakistan P N 2018-08-15Philippines, Rep. of the P N 2018-08-15Poland P N 2018-08-17Portugal P N 2018-08-17Qatar ORomania ORussian Federation O N 2018-08-14Saudi Arabia OSerbia PSingapore OSlovakia OSlovenia P N 2018-08-16South Africa P Y 2018-08-17Spain P N 2018-07-17Sweden P Y 2018-08-17Switzerland PThailand P N 2018-07-11Turkey P N 2018-08-15Ukraine P N 2018-08-16United Kingdom P N 2018-08-16United States of America P Y 2018-08-15Vietnam P N 2018-08-17

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P-members O-members Non-members TotalY : comments 8 0 0 8

N : no comments 31 3 0 34- : no response 4 8 0 12

NotesP-members with no response: Albania; Greece; Serbia; Switzerland

*Comments rejected because they were not submitted in the IEC Comment form.

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Date Document Project Nr.61/5700/DC 60335-2-53

MB/NC Line number(e.g. 17)

Clause/ Subclause(e.g. 3.1)

Paragraph/ Figure/ Table/

(e.g. Table 1)

Type of comment

Comments Proposed change Observations of the secretariat

1 MX1 ge The MX NC has no comments on this proposal

Noted.

2 ZA Supported without comments Noted

3 AT1 ge This proposal is good for safety and makes the standard more clear.

Noted

4 CA-01 all all - ed. The newly defined terms must be bolded throughout the standard.

Bold defined terms. Accepted

5 DE 1 ge “Continuously monitoring” is not a good definition for operations in public saunas.

Delate in all proposals “continuously monitoring” by “supervised operation”.

Accepted in principle, see US3.

6 SE 01 ge The Swedish NC is of the opinion that this proposal should not be accepted. If it should be considered for acceptance it requires changes. See our comment below.

Noted

7 NZ1 1-9 1 ed The propose text does not clarify or add anything to the existing text

Delete the proposed text. Accepted partly.Note 101a on lines 6-9 is deleted.No change to lines 1-5.Proposed text on lines 1-5 clarifies the difference between public sauna and sauna located in blocks of flats. Different requirements apply for different applications. Sauna heating appliance located in public sauna shall be operated supervised. Sauna heating appliance located in blocks of flats shall be provided with a timer switch.

8 DE 2 3-5 1 te The German NC support the proposal Noted

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(e.g. Table 1)

Type of comment


9 DE 3 6-9 1 te The gym is in our opinion a typical place where the heater is not in supervised operation.

Add gym in the line 7 after “hotel saunas” and delete gym in line 8. Add Thermal Baths in line 8 after “swimming pool”

Covered by the deletion of note 101a. See NZ1.

10 US1 6 thru 9 Note 101a - ge In some countries and jurisdictions, different sauna locations may require monitoring. This note does not provide any useful information and may not be accurate in all countries.

Delete Note 101a. Accepted.

11 DE 4 10-30 3.102 te The German NC support the proposal but we are missing protective devices (see note 101 in 3.109)

Add the protective devices in the drawings Not agreed but a new note is to be introduced in order to clarify the situation.The intention of figures is to clarify terminology of this standard. Due to the several applications, it is not reasonable to give all possibilities. Protecting devices can be located in several places depending on the application (in sauna heater, in control board etc.). It is essential that sauna heating appliances fulfils requirements given in this standard.The following text is proposed to be inserted in NOTE 101: Protective devices are part of a sauna heating appliance and they may be situated in different locations.

12 NZ2 11 -30 3 te If the controls are not on the control board then what is on the control board?

Clarify our comment with respect to Figures 101a and 101c.

No change.Controls shown in figures are describing user interface. Control board includes e.g. relays and other components to adjust

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(e.g. Table 1)

Type of comment


the power to sauna heater.

13 DE 5 34-36 3.109 te The German NC support the proposal Noted

14 US2 34 - 49 3 ed The newly defined terms and some previously defined terms are not indicated in bold type throughout the proposal.

Review proposal to format defined terms in bold.

Accepted.


16 NZ3 39-42 3.110 te For many years a timer has been referred to in Part 1 and many Parts 2 without the need for a definition. We see no need to define it in this Part 2 as it will cause confusion when the term is used in other standards in the 60335 series and in clauses of Part 1 where the term is used.

Delete lines 39-42. Not agreed.Term “timer” is not defined in IEC 60335-1. This term is taken from IEC 60730-1 and it is essential for the safety of the sauna heating appliance to make a difference between timer and timer switch.


18 NZ4 43-45 3.111 te Isn’t this just a programmable timer? Change the term to programmable timer where it is used throughout the draft and delete lines 43-45.

Not agreed but a new note is proposed to be introduced in order to clarify the situation.Term “timer switch” is not defined in IEC 60335-1. This term is taken from IEC 60730-1 and it is essential for the safety of the sauna heating appliance to make a difference between timer and timer switch.It is proposed to add a following note to 3.111:NOTE - Timer switch includes also a programmable component or a circuit.

19 NZ5 47 3.112 te This is a recessed sauna heater. Replace installation by sauna heater. Not agreed. No change.A term “sauna heater for recessed

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(e.g. Table 1)

Type of comment


installation” is only used in IEC 60335-2-53 Ed. 4.1. Maybe a term could be changed to a “recessed sauna heater” or a “hidden sauna heater” but this change requires that the same modification is to be done throughout the whole document.

20 DE 8 47-53 3.112 102a 102b te A test according to 19.102 is not possible in the installation situation according to Figure 102.

Replace Figure 102 by Figure 102a and add Figure 102b after Figure 102a. Replace in line 53 the text Figure 102 – Example of recessed installation by text Figures 102a and 102b - Examples of recessed installation.Add “directly” in line 49 after out of

Accepted.Figures are examples.

21 US3 3.113 - te The term “continuously attended” is used in the existing -2-53. The proposed revisions now use the term “continuously monitored”. However, neither term is defined in the current text or the proposed text. We support using the new term “continuously monitored” but believe there should be a definition added to define this term.

Add new Clause3.113 continuously monitoredBeing under supervision by trained person(s) which can be physically present to observe first-hand, or a combination of physical presence and remote viewing of data to indicate condition and operation of the appliance. Information to be assessed during monitoring include the presence of users inside the sauna, door open/closed, the temperature of the sauna, the humidity level in the sauna, and any other information directed to be monitored by the instructions.

Accepted partially but modified. See DE1. According to DE1 term “continuously monitored” is replaced by” supervised operation”.The Finnish NC is pleased to support the first sentence of this proposal but not the second sentence. Second sentence does not belong to the scope of this Publication.It is proposed to add a new term and a new definition as follows:3.113 supervised operationsupervision by monitoring person(s) which can be physically present to observe first-

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(e.g. Table 1)

Type of comment


hand, or a combination of physical presence and remote viewing of data to indicate condition and operation of the appliance


23 NZ6 60-61 7.12 te We do not understand what is meant by “types of control board”

Explain the term types of control board with examples.

Accepted in principle.It is essential that a sauna heater and a control board are compatible with each other. It is proposed that the text will be modified as follows:The manufacturer shall state in instructions suitable controls and control boards which can be used with the sauna heater unless they are integral parts of sauna heating appliance.

24 NZ7 65 7.12 te Appliances having a timer switch should be continuously monitored to make sure that when they switch on via a delayed start they are being monitored.

Delete “or timer switch” Not accepted but we propose to revise text. See comment US5 for modified text.The proposal of the Finnish NC tries to solve the concern by adding a new requirement for sauna heating appliance provided with a timer switch. Such construction shall fulfil the test 19.101 in order to increase safety

25 CA-02 65-69 7.12 - te. The 2nd sentence (on line 66) should also include timer switches.

Considering the different modes of operation

Modify the proposed text as follows:

The instructions for appliances for public

Not agreed.The main goal of this proposal made by the Finnish NC is to

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(e.g. Table 1)

Type of comment


and the deletion of the 3rd paragraph (lines 71-72 of the proposal), the required inspection should also apply in conditions other than just restarting a timer.

saunas that do not have a timer or timer switch shall state that the appliance shall be continuously monitored. The instructions for other sauna heating appliances and infrared emitting units which are not continuously monitored and which have a timer shall state that the sauna room or cabin is to be inspected before either restarting the timer a timer, setting a timer switch, initiating a stand-by mode for remote operation or by switching on the appliance by a remote operation.

increase a safety by adding a new requirement for a sauna heating appliance provided with a timer switch. Such construction shall fulfil the test 19.101.

In Finland thousands of saunas are located in blocks of flats and residents of that building are allowed to use the sauna. Such sauna heating appliances are provided and operated with timer switches. Nobody will check the sauna room before the next cycle. Although none fires have been recorded, we would like to clarify the existing text and increase the safety.

26 US4 66 7.12 ed This is not a requirement (shall), but the wording that is to be included in the instructions. Change back to original wording.

Replace “shall be” with “is to be” Accepted

27 US5 67 7.12 te The proposal in Clause 19.1 (lines 112-113) indicates that even appliances that are intended to be continuously monitored should have these instructions.

Delete “which are not continuously monitored and”

Accepted in principle but the proposed modification does not solve the real problem. It is proposed that the whole paragraph will be modified as follows (see also US10):The instructions for appliances for public saunas that do not have a timer or timer switch shall state that the appliance is to be operated supervised.

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(e.g. Table 1)

Type of comment


The instructions for sauna heating appliances and infrared emitting units which have a timer shall state that the sauna room or cabin is to be inspected before restarting the timer or by switching on the appliance.

US6 69 7.12 ed Delete “a” before remote operation Delete “a” Accepted28 CA-03 76-81 7.12.1 - ed. For consistency with the proposed change in

7.12, both timers and switch timers should be referred.

Replace the word “timer” in the proposed text with “timer or timer switch”.

Accepted

29 DE10 78-90 7.12.1 te The German NC support the proposal Noted

30 NZ8 78-81 7.12.1 ed We prefer the existing text. Delete the proposed text. Noted but not agreed.

31 US7 79-81 7.12.1 ed This is not a requirement (shall), but the wording that is to be included in the instructions. Change back similar to original wording.

Delete “there shall be” from line 79Delete “for the monitoring person” from line 80Add “is to be installed where visible to the monitoring person.” to the end of line 81

Accepted.Accepted.

Accepted.

32 NZ9 85 7.12.1 ed Some words are missing concerning the introduction of 19.102

Add the words “as appropriate” after “19.102”

Accepted

33 DE11 94-110 19.1 te The German NC support the proposal but we are missing pre-time selection mode.

Add after timer switch in line 100 “and with time pre-selection mode”

Accepted in principle but modified as follows:“or with time pre-selection mode for remote operation”.

34 NZ10 94-113 19.1 te We can only accept the change proposed in lines 108 to 110. The other changes are adequately covered by the existing text.

Delete the proposal except for the change proposed lines 108 to110.

Not accepted.This proposal was made to clarify the existing text and in order to improve the safety of sauna heating appliances having timer switch.Remote operation of household appliances including sauna heater appliances is increasing

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(e.g. Table 1)

Type of comment


all the time. The existing standard does not respond to this challenge and to future technical solutions enough. Therefore more specific requirements are needed in order to ensure the safety and to take into account future requirements concerning smart homes etc.

35 SE 02 94-100 19.1 Te Modification is too design restrictive and may force manufacturer to use patented techniques to create a viable solution. The intended increased safety will not be fulfilled with this change.

Keep the wording as it is. No change.This test applies also to sauna heater appliances provided with timer switch.Test 19.101 is already in IEC 60335-2-53 Ed. 4.1.The proposal made by the Finnish NC is to increase the safety of sauna heating appliances provided with timer switch by adding a new requirement for such construction.

36 US8 99 19.1 ed Grammar Change 2nd “is” to “are” Accepted.

37 US9 108 19.1 (various)

ed Correct defined term here and throughout proposal

Change “sauna heater appliances” to “sauna heating appliances”

Accepted

38 DE12 111-112 19.1 te Rationale: continuously (uninterrupted) monitoring of any sauna is nearly impossible over a period of several hours. Therefore the interlock requirements of 22.108 shall remain without any change.

Delete line 111-113 Not agreed.Sauna heating appliances intended to be operated under supervision in public saunas do not require such protection devices (interlock). This is already stated in Ed.

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(e.g. Table 1)

Type of comment


4.1. The proposal of the FINC was only to clarify the existing text of Ed. 4.1. (Note that “continuously monitoring” is agreed to be changed to “supervised operation”. See US3, DE3.)

39 US10 112-113 19.1 te A marking requirement should not be included in clause 19. See US comment on line 67 that makes this marking applicable for all public sauna installations, including public saunas intended to be monitored.

Delete “and they are supplied with the instructions that state that the sauna room or cabin is to be inspected before switching on the appliance”

Accepted. See US5

40 US11 112 19.1 - ed If not deleted as suggested in previous US comment, “they are” should be deleted to improve grammar.

“…monitored in public saunas and they are supplied with the instructions that stating that the…”

Covered by US10

41 DE13 116-117 19.1 te The German NC support the proposal Noted

42 US12 116-117 19.1 Te It is unclear from this wording if the test of 19.102 is to be conducted only as an alternative to the test of 19.101 or if it is required on all sauna heaters intended for recessed installation. If the intent is to waive the test of 19.101 for recessed installation heaters, and subject all recessed installation heater to the test of 19.102, then the proposed change is suggested.

Replace lines 116-117 with the following:Sauna heaters intended for recessed installation with air outlets in the wall of the sauna room are not subjected to the test of 19.101, but are subjected to the test of 19.102.

Accepted

43 NZ11 118 19.13 ed The text in the modification is a modification to the first entry in Table 9 and the last paragraph of 19.13 of Part 1.

Delete line 118 Accepted

44 US13 118 19.13 ed These items are modifications of existing Part 1 requirements, not additions

Delete line 118 Accepted

45 NZ12 121 22.51 ed The text in 22.51 is a modification to the text in Part 1 that states “There shall be a visual indication on the appliance showing that the appliance is adjusted for remote operation”. It is not an addition to this text.

Delete line 151 Accepted but line 121 is deleted, not line 151

46 DE14 123-134 22.103 te The German NC is in opinion that using without time limit is not safe.

Delete line 125-126. Add “Appliances, shall be provided with a timer in line 125.

Not accepted.Sauna heating appliances operated under supervision do

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(e.g. Table 1)

Type of comment


not require certain time limits. Nothing has changed with regard to existing Ed. 4.1

47 NZ13 123-134 22.103 te We doubt that such a change to the existing text is necessary and as proposed is confusing. However, the existing text should be clarified by making reference to infrared cabins.

Review the standard to also refer to infrared cabins where appropriate. For example in 22.103 add “and public infrared cabins” after “public saunas”.

Not accepted.Expression “appliances” is used often in Ed. 4.1 and this expression covers also infrared cabins.The FINC has only clarified the existing text because text of Ed. 4.1 has raised different interpretations among users of this standard.

48 US14 126-131 22.103 te The requirement in the second and third sentences is related to the timer required in the first sentence, so the wording can be simplified.In addition the term “similar locations” could be unclear.Suggest simplifying to public locations and household locations (or use).

Replace “having timer switch for use in locations where appliance are operated without continuous monitoring” in lines 126-128 with “for public saunas”Delete “and similar” from line 131

Not accepted (1st part).This requirement is intended for a sauna heating appliance provided with a timer switch. It is not intended for sauna heating appliances intended for public saunas.Sauna heating appliances operated under supervision do not require certain time limits. Nothing has changed with regard to existing Ed. 4.1.Accepted (2nd part).To be modified as follows:Appliances for household use, the operating period of the timer shall be limited to 6 h, automatic restarting is not being allowed.

49 US15 129, 132

22.103 ed Improve grammar Add “any” before “24 h period” Accepted

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(e.g. Table 1)

Type of comment


Delete “is” from line 132

50 US16 133-134 Note 101 - ed Delete Note 101, since this is not needed and cannot be controlled by the appliance manufacturer.

Delete Note 101. (If not deleted, replace “block” with “blocks”)

Accepted and note is to be deleted.

51 DE15 139-142 22.108 te The German NC support the proposal Noted

52 NZ14 139-141 22.108 te The propose text does not clarify or add anything to the existing text

Delete the proposed text. Finnish NC disagrees because the original text in existing Ed. 4.1 is unclear for users of this standard.Intention is to clarify the requirement

53 NZ15 144-145 22.108 te Some words are missing concerning the introduction of 19.102

Add the words “as appropriate” after “19.102”

Accepted

54 DE16 148-149 22.110 te Modern displays no longer have pilot lamps but icons or similar options.

Add in line 148 and 151after pilot lamp,icon or other display options.

Accepted

55 NZ16 148-153 22.110 te What other indications are envisaged other than a pilot lamp

Clarify “other indications” Covered by DE16

56 US17 148 22.110 ed Correction Replace “appliance” with “appliances” Accepted57 CA-04 150-154 22.110 - te. The CANC believes these new requirements

for “delayed switching on mode” should equivalently apply to “stand-by mode setting for remote operation”.

Editorial note: the word “visual” may be added prior to “indication”.

Modify proposed text as follows:

If a sauna heater appliance is provided with a delayed switching on mode or a stand-by mode setting for remote operation, then it shall be provided with a visual indication (e.g. pilot lamp) showing that the delayed switching on mode has been activated and means requiring two independent actions before delayed switching on the mode can be activated.

Accepted together with DE16.Modified as follows:If a sauna heating appliance is provided with a delayed switching on mode or a stand-by mode setting for remote operation, then it shall be provided with a visual indication (e.g. pilot lamp, icon or other display options) showing that the mode has been activated and means requiring two independent actions before the mode can be activated.

58 US18 150 - 152

22.110 ed Use existing wording used elsewhere in the standard.

Replace “delayed switching on” with “delayed starting” throughout proposal

See. Comment CA04

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Annex of DE.doc

Figure 102a Figure 102b

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