tape conveyor: declaration of conformity or incorporation?

[reggio]

hi, buying a conveyor belt with a special accessory, we realize that the supplier redirects the Declaration of incorporation instead of the declaration of conformity , having to resell it as we have received it We would like to know if it is right to receive and then to provide the declaration of incorporation or instead the declaration of conformity.recovering what is reported in the legislation

"The car is a
— together equipped or intended to be equipped with a system of drive other than human or direct animal force, consisting of parts or components, of which at least one mobile, connected solidly for a well determined application,
— together with the first indent, to which only elements of connection are lacking to the site of use or connection to the sources of energy and movement,
— set of the first and second indent, ready to be installed and which can only work after being mounted on a means of transport or installed in a building or in a building,
— sets of machines, of which the first, the second and the third indent, or of almost-machines, referred to in letter g), which in order to achieve the same result are arranged and commanded in order to have a solid functioning,
— set of parts or components, of which at least one mobile, connected solidly and intended for weight lifting and whose only source of energy is the direct human force"

"the quasi-machine is a set that constitutes almost a machine but which alone is not able to guarantee a well-defined application. a drive system is a quasi-machine. "

... I totally disarm myself and redo all to a nice "go to tastes, depends as you see it" :frown: in the sense that at mè these definitions do not define a good nothing, I do not understand the difference ... I ship and find this:

Let us make a clearing example: the wiper is a machine and can also work alone and detached from the car, but its intended use is to be installed on the car and to be connected to it and dependent on it, in this application the wiper is “almost-machine” and the complete vehicle is the “machine”.

... but a wiper is not really a

together equipped a drive system other than human force or direct animal

for example his electric scooter

composed of parts or components, of which at least one mobile

certain is mobile: Turn around all the time!

connected with each other solidly for a well determined application.

all connected inside a metal casing, with a well determined application: sweeping the glassesso the wiper is a machine No?

because if we take for good reason we say

but its intended use is to be installed on the car and to be connected to it and dependent on it, in this application the wiper is “almost-machine” and the complete vehicle is the “machine”.

then whatever will have a job that plans to be installed or connected or dependent on other ...
the conveyor belt "transport" but only if connected to the current via an electrical picture and only if it is loaded by something else, means that even the conveyor belt without electrical system is “almost-machine”?
do you have the strength and patience to explain to me the general logic and also to tell me if it is right to receive and then to provide the declaration of incorporation or instead the declaration of conformity for the tape in question?

 

[meccanicamg]

the conveyor belt is not a machine because if you put it on the ground and turn it on it does not do anything. when you insert it into a plant and something or someone puts the pieces in the input and something or someone picks up the piece at its output + electric picture and control buttons get a machine that does the work finished.
so it is attached b or attached 2....so the tape has the embedding certificate and not the c.
applies to vibrating hoppers, linear and circular vibro power supply, rollers and chainways sold as such, without knowing what is attached to the plant.

 

[reggio]

the conveyor belt is not a machine .. and routes to chains sold as such, without knowing what is running in the system.

hello and thank you for your attention, if I can take advantage of your patience to ask you:

If you give it a power plant and turn it on but no one loads it and downloads it continues to be a non-machine?
Does this mean that the incompetence of "transforming" the tape from almost machine to machine falls on who will add the last component that loads and downloads the tape or strip line complete with electrical system?

without knowing what's in the system.

How do I rule in this case?
the supplier says "I only sold you a tape without knowing how you use it: it's almost machine"
the client instead says "but as on offer you wrote <nastro ad="" adatto="" bello="" caricato="" con="" da="" esistente="" essere="" h="" kg="" macchina="" x=""> You knew what was going on in the plant: it's a machine"
and why?</nastro>

 

[meccanicamg]

the machine directive comes out because even if you buy from the company pinco the tape and tell him that it has to replace the existing one, who has in hand the technical management of the system is obliged to make a new document of conformity of the system itself, because the c of the system consists of the individual machines and almostmachines indicated in the technical dossier and numbered with of the molecules.
If you replace an electric motor with an identical one you do not need to remake the c. if you change use destination from electric motor to hydraulic you have to remake the ce.
then many let go and many changes are done.

 

[meccanicamg]

But we are in Italy and things are never clear.
here. http://www.m2servizi.it/upimg/directive machines/disp dir 2006 42 e dlgs 17 2010.pdfpage 9 says the exact opposite.

while all the builders make the incorporation https://www.montech.com/docs/ba/conveyors/mtb_ba-100109_ita.pdfwe say that it is a very border line...and anyway the conveyor belt if to work safely needs protection and sensors to make it work... here is 100% incorporation.

the old 98/37/ce was certain that the conveyor belt was incorporated Annex 2b.
with the new 2006/42/ce instead of clarifying has messed up everything saying that they are all machines that even incomplete do their job

 

[gerod]

I disagree with meccanicmg but as you say, every manufacturer does what he wants.
If you go to read well the guidelines of the machine directive, the almost machine does not have a well defined use destination.
ok, the conveyor belt carries something, its function is well defined, performs a translation of something. in fact those who design it think at the maximum reach, at the number of turns, etc....
and then if they sell it (as in the case of reggio) with special accessories I would say that who designed it knew what was going to do.
the question of the machine put in the middle of a yard that does nothing and therefore it is almost machine is, in my opinion, a convenient position that de-responsibility the manufacturers: too easy to say that it is not a car.
then there are those who mark them but sell them with declaration of incorporation: but how, first they say it does not comply with the directive and then they put the mark on us? They can't!! !

we say that it is a very border line...and anyway the conveyor belt if to work safely needs protection and sensors to make it work... here is 100% incorporation.

I'm sorry, but it's not like this: the guideline says that a car, although without security components, always remains a car! here is the comment § 46

machines which are able to fulfil their own specific application but which lack only the necessary means of protection or safety components should not be considered almost-machines.

I add that for conveyor belts there are harmonised standards of type c (en 619, 620).
I see it so because on the topic I banged my nose and looked good at the guidelines (I also wrote an article published on wki).
a greeting

 

[meccanicamg]

Second Directive 2006/42/EEC

(g) 'quasi-macchine': sets that make up almost one
machine, but that, alone, are not able to guarantee
a very determined application. a drive system
It's almost a machine. the almost-machines are
only intended to be incorporated or assembled to
other machines or other machines or appliances
constitute a machine governed by this Directive

Therefore if it proves that the conveyor belt transports, as much as an drive drives...but what is not indicated on either of the two objects, neither the direction, the sense (forwards/back....or vice versa) can be considered a quasimachine.

do not tell me that a drive is not a set of assembled objects, of which at least one mobile device is not known that connected to a motor moves it?

As always the laws are interpreted...in place of being written clearly.... one day the Martians will teach us that we have thrown a lot of years to think nonsense :finger:

 

[gerod]

As always the laws are interpreted...in place of being written clearly.... one day the Martians will teach us that we have thrown a lot of years to think nonsense :finger:

In fact!
There are two threads of thought and, as you said, the introduction of qm has done nothing but create even more confusion.
I'm on the side of who says that the qms are few.
What you say is also shared.
Hi.

 

[320i S]

to me has explained that everything goes to who drives the mechanism:

is machine if it is operated directly by an operator to move something (so it needs the statement c)

It is almost machine if it is another machine to operate it, in this case the final certification is required to the entire plant in which it is, then to the conveyor belt, just the declaration of incorporation.

the wiper is almost machine because in today's vehicles, it can be operated by a sensor (rain sensor) or by the spray control, the control from the lever, is not at this point direct, but sends a signal to the control unit that controls the engine of the windshield.

 

[gerod]

I think you were wrong.
It's not like that.
the interpretation that has given you is not correct.
I ask you: where is written is what?
Thank you.

 

[reggio]

the almost machine does not have a well defined use destination.

... oh a mè stà definition pare da mentecatto... or more easily I am still not able to imagine an example of almost machine without a well defined destination ... to mè comes in mind only the madman who says "was waiting for me to design a nice car today.. ehm no, a beautiful almostmachine! with a nice complex mechanism ... that does not serve a blessed min#]i@" :tongue: (https://goo.gl/zv8rjj) (https://goo.gl/nqymxk)

the question of the machine put in the middle of a yard that does nothing and therefore it is almost machine is, in my opinion, a convenient position that de-responsibility the manufacturers: too easy to say that it is not a car.

... unfortunately I agree, the almost machine does not exist and the dicks are left to those who touch him:frown:
at this point the definition could be: "the hot potato, the ball, the bomb are an example of almost machine that when you get in your hand turns into a car"

I add that for conveyor belts there are harmonised standards of type c (en 619, 620).

ahiii another painful key that makes me turn them fast...
"harmonised standards" pieces of paper (not even hygenic), rarely translated from the English language so as not to be missed the possible further imaginative interpretation, often accompanied by explanatory drawings dating back to the Paleolithic, rarely economic but still much less often useful, certainly complete with links to other norms and/or/or directives to buy... :frown:
it is enough to quickly browse the en 619 to realize that those who have written it of conveyor belts really understands little, then for charity, the really useful tips, basically: It will spoil everything that no one can approach and greet me so much maintenance and costs.

I see her like this because on the subject I banged my nose and looked good at the guidelines

say in general or about tapes?

I also wrote an article published on wki.

Oh interesting this, link? :finger:

 

[gerod]

I agree, but it is the state of the technique and any judge would refer to that. If you are better and make a safer tape well come, but the conveyors in general are and you can't do more than much to make them safe.

I did not mean that the topic refers to tapes, in general to many types of presumed almost machines.

there is no link, it is a publication in the magazine http://www.utilla.it/bancadati/metodi_di_identificazione_delle_quasi_macchine-1119019.aspx

 

[320i S]

I think you were wrong.
It's not like that.
the interpretation that has given you is not correct.
I ask you: where is written is what?
Thank you.

It's not a "written" thing, I've explained it so loudly.
So I ask you, in what one equipment operated and managed by another (and therefore inside a plant), is not called "any machine"? (even with a practical example).

 

[reggio]

I agree, but it is the state of the technique and any judge would refer to that. If you are better and make a safer tape well come, but the conveyors in general are and you can't do more than much to make them safe.

hi, I am no longer good, what I mean to "lament" of this way of standardization, which for other, if I do not issue "suggerations" or at most "shared suggestions" not certain of law, is that their purpose, even so hidden is to pass to others the problem, when they should or
Shut up!
or
give precise indications (it does not mean to give the mm away for each machine or things like this, but to be understandable) and really feasible.

otherwise, in this way, risks (but also reading here seems more a certainty) to make only confusion and the best becomes what he interprets to pleasure, remove protections, risks more, sells the car to your place and fortunately the fugue because no one, fortunately, hurts: I don't think that's the direction towards recognized quality and safety.
as the usual laws would suffice and clear: even here we are at the exact opposite :

... even if ... the norms of machines and en are European real, not only Italian ... so also European colleagues are confronted with all this "clearness"?

So I ask you, in what one equipment operated and managed by another (and therefore inside a plant), is not called "any machine"? (even with a practical example).

I accompanied the appeal:biggrin:

 

[pollo]

hi, I am not better, what I mean "lament" of this way of standardization, than for other, if I do not issue "suggestions" or at most "shared suggestions" not certain of law, is that their purpose, even so hidden is to pass to others the problem.. .

call them as you want, but if you do the machine respecting the harmonized standard (and keep in mind that the harmonized standards are usually not made by the first one, but by experts from various sectors, often coming from manufacturers and users) you have the maximum European technical committee behind and in front of an investigation or contestation is not negligible.
If you do it according to your standards (always you have them), it is up to you to show that you have reached the same level of safety as the norm ) and it is not easy to prove it).
Moreover, it considers that the directive on Article 4 clearly states:
art. 4
(presumption of conformity and harmonized standards)
...2. machines built in accordance with a harmonized standard, whose reference was published
in the Official Journal of the European Union, they are presumed to comply with the essential requirements of
safety and health protection covered by this harmonized standard.

for the rest of the considerations on the rules can be discussed, but they are only our opinions (and certainly not authoritative, at least my ones).

Finally, I fully share gerod on qms, apart from that I am more drastic: qm do not exist and my customers always recommend to request in specification as a machine that so much a destination of use always have it (and eventually manufacturers declare it as such, providing the limits of use).

Hi.

 

[Ing. Rigon]

it would be interesting to read the statement of incorporation

Is it possible?

 

[reggio]

call them as you want, but if you make the car respecting the standard harmonized ..

for the rest of the considerations on the rules can be discussed, but they are only our opinions (and certainly not authoritative).

hi, it was not to polemize (well only a little) but to say that a norm that recommends me "do the thing done well and that no one hurts." is sacrosanct, but a little poor as deepening and experience that passes to me builder. . .

if you think that here, in 4 cats, we have not yet managed to define and agree clearly on what is and what is not a qm, and if you "allow" to say (in the good sense)

to my customers I always recommend to request in specification as a machine that so much a destination of use always have it

means, for me, that "experts" were not so clear, and if they are not clear they are not even help (according to me) ...

it would be interesting to read the statement of incorporation
Is it possible?

Who were you talking to?

 

[pollo]

the problem is not what is or is not a qm, for that there is the definition to read and apply without interpreting (the interpretations leave them to the magistrates and judges of turn).
the question is whether your tape is qm or not. builders of course prefer to say that they provide qm, passing the blind on to the user, which in turn believes that if it were a machine would be more protected by putting down the responsibilities on the manufacturer (something by itself false as the employer must provide equipment complying with the directive and not only with declaration of conformity).
on our own we can only apply the definition of qm to your gadget and see if it returns: to the conveyor belts such verification has already been made by others and, if I do not remember badly, came out that it was machine (I ask confirmation to gerod, that it is he the expert).
I have never been able to apply the definition in full, especially at the point of the use destination, from which my belief that they do not exist.

more than the statement, it would serve the user manual, where the manufacturer says what he delivered.

 

[gerod]

the qm exist but are few and are those that are contained in the guidelines of the directive (driven systems, unscheduled robots - read without a destination of use).
I agree with chicken that then many say "it's not a machine" and then release the ddi without, for example, list the res to which it conforms. When I see an incomplete ddi, I have doubt and context.
I see marked tapes and qm tapes to which to give reason?
I am for the analysis of definitions and on those the manufacturer makes its own assessments.
if one has doubts that he interjects an on and asks.
many manufacturers still release ddc and/or manufacturer statements citing 89/392/cee, .... the degree of knowledge is still very lacunous, don't you think?
"the almost machines do not exist" I like and share!
We're not advising here anyway. if one wants an official opinion takes a professional and pays it. we are giving free general information and we are reasoning together going to take various legal references.
Hi.

 

[Ing. Rigon]

and then the declarations of incorporation for the almost never 95% machines of the cases) report the res that have analyzed and that the almost machine satisfies.

This year only once I received a declaration of an almost machine (which was actually an almost machine) , this statement was written by a German engineering company and formally was unexceptionable.

without entering into the merit that then the almost machine strictly respected what stated, the first impression that one is made is to have to deal with designers/constructors who know what they are talking about.

then you can disquise on the ankles: machine, almost machine, who certifies all together of almost machines, where I arrive and where you arrive etc. etc.

so first you must know well and know how to argue the choices faced.

for me the machine or quasi-machine question (other than the cases where the distinction is clear) are only formal bureaucratic aspects and other is the substance and necessity that the legislation imposes.