difference between 'applied' and 'applicable' in the machinery directive

[Elet88]

Good morning to all,
in the creation of technical dossiers (ft) and relevant technical documentation (dtp) I am encountering in a snare that needs this reasoning to be explained:

ft:
Does my machine have to comply with all the res (all) prescribed by the directive? the answer is "yes", or the directive loses validity. However my car is not equipped with seats: how to do with the res 1.1.8 "sailes"?
It is not Applicable but not because you do not want, but because there is no seat. And I'm gonna put him in ft.

dtp:
design my machine according to the final installer; Does it have to comply with all the res (all i) prescribed by the directive? the answer is "no", because the manufacturer of the target machine deals with the res that I did not apply because unable to respect them for obvious design reasons.
the declaration of incorporation will contain the list of res applied (e non applicabili , because with the almost-machine I decide what to respect and what not.

hoping that my reasoning is correct, I seek confirmation to the following question 1 and a possible answer to the question 2:

1. the machine (ft) can not respect only the res that cannot be applied (non applicabili). Right?

2. the quasi-machine (dtp) may not respect any res because I declare it in the statement and the installer will take care of filling the missing res. but therefore, in a quasi-machine, the res "1.7.4.2 content of the instructions" is never applied since there is no declaration of conformity but that of incorporation?

Thank you!

 

[pollo]

1. true. It is also true that if you do not have seats, its risk is not there, as if you do not have laser the risk there is and the point is not applicable.
2. more than you decide, you must see what risks apply to your qm. if there are risks, or solve them as res, and write in the statement that complies with the res, or write in the manual how to solve the problem and in the statement you do not put that res. you have the obligation to list only compliance res

 

[gerod]

1. How many denials!!!! not applicable res. I am by definition and therefore how do you comply with them? do not apply them and justify it.
2. Wait... I think you're messing up.
you must indicate in the declaration of incorporation the equivalent res, those conforming to your quasi-machine. the content of the instructions is worth, in my opinion, even for the almost machine! It is true that they say that the declaration of conformity must also be provided with the instructions and therefore not the declaration of incorporation .... I always did a similarity between car and almost car.

 

[Elet88]

hello and thanks for the answers.

the core of the issue was also in the title of the thread: res "applied" and res "applicable". It seems to me that this distinction exists between m and qm, but I do not see any trace of it in the directive and it only happened once I heard the debate on this aspect (according to me very important).

the res 1.7.4.2 I find it very ambiguous for a simple gap to fill (it was enough to indicate that point c. does not apply to qm).

 

[franzi fabio]

because the manufacturer of the target machine deals with the res that I did not apply because unable to respect them for obvious design reasons. the declaration of incorporation will contain the list of applied res (and not applicable, because with the quasi-machine I decide which to respect and which not).Are you sure? Be careful because on almost machines it is easy to slip.
If your machine is a machine to be inserted in a line and for this it is deprived of some protections or security (typically happens) it is still a machine, in my opinion, but you can not release declaration of conformity and there.
for d.m. agreements between the parties have less value than a drop of water in the desert.
a board evaluates well and informed.

 

[pollo]

Wait.
If it is a machine, then it has a destination of use and must have the declaration of conformity, regardless of whether it is to be put in a set or not.
vice versa, the almost-machine does not have a well-specified use destination.
If the machine with other machines (or almost-machines) forms a set, then the assembly will have to evaluate physical and logical interfaces and make a single declaration of conformity (of the whole), but the initial machine remains.
It is true that "typically happens", but it is wrong, it is a false escape from azzeccagarbugli, the guidelines to the directive are clear, it is the destination of use to tell me if it is machine or almost-machine, not the choice of the manufacturer.

 

[Elet88]

Well, if it's obvious that you don't have a statement, I don't think I wrote the opposite. when I sell a qm the buyer has the list of applied ress (here was the point: applied or applicable?) and it will be his care to fill the remaining ress.

I'm not sure of anything to this world... ... but if not, then how is it?

 

[Elet88]

2 extracted from the Machinery Directive:

- 1. Annex I, declarations. b: declaration of incorporation of almost-machines.

point 4, recitation:

"an indication by which it explicitly states what essential requirements of this Directive are applied e rispettati [...]"

- 2. Annex. a: technical dossier for machines.

play:

(i) a list of essential health and safety requirements Applicable to the car [...]so I would say that the mystery has been dissolved.

 

[Fulvio Romano]

ft:
Does my machine have to comply with all the res (all) prescribed by the directive? the answer is "yes", or the directive loses validity. However my car is not equipped with seats: how to do with the res 1.1.8 "sailes"?
It is not Applicable but not because you do not want, but because there is no seat. And I'm gonna put him in ft.

Okay, here we understand that non-applicable res are ignored by demonstrating why.

dtp:
design my machine according to the final installer; Does it have to comply with all the res (all i) prescribed by the directive? the answer is "no", because the manufacturer of the target machine deals with the res that I did not apply because unable to respect them for obvious design reasons.
the declaration of incorporation will contain the list of res applied (e non applicabili , because with the almost-machine I decide what to respect and what not.

Let's talk about machine manufacturer and not installer. in a near car if you do not comply with a res you do not because you chose it randomly, but because you show that it is not possible to comply.

2. the quasi-machine (dtp) may not respect any res because I declare it in the statement and the installer will take care of filling the missing res. but therefore, in a quasi-machine, the res "1.7.4.2 content of the instructions" is never applied since there is no declaration of conformity but that of incorporation?

Absolutely not. the almost machine have the instructions of use and maintenance. Have you ever seen a robot being sold without manual?
and in any case the manufacturer of the machine must be put in condition to respect all the res. the manufacturer of the almost machine must write which are the missing res that must be met.

and then, as my mentor said, "the almost machines do not exist." :

 

[exxon]

in a near car if you do not comply with a res you do not because you chose it randomly, but because you show that it is not possible to comply.

or because you need the thing to the almost machine integrator in the complete machine.

 

[Fulvio Romano]

or because you need the thing to the almost machine integrator in the complete machine.

No. you can't hand over the res supplement that is suitable for almost machine level.

 

[exxon]

No. you can't hand over the res supplement that is suitable for almost machine level.

No, I disagree. I give you the example of a concrete case involving one of the last projects.

almost-machine with "on view" dense wheels in a compartment accessible from the opposite sides. one side is closed by a grate "normally" the other not.

the reason is that the almost-machine must be integrated into the line, by fitting it a structure that will make inaccessible the side left uncovered.

the documentation is specified the risk and it has been indicated that the assembly must be such that the access to that area is physically prevented.

 

[pollo]

and in your file you will have shown why in that almost-machine you cannot put the carter.
Now I'm a devil's lawyer. Is your supply almost a machine because it responds to the definition, or is it a non-compliant machine and requires other protection?

 

[exxon]

and in your file you will have shown why in that almost-machine you cannot put the carter.

No. I couldn't put it.
I could have put it, but I didn't put it because it was useless in the final configuration of the machine assembled. the danger exists in the almost machine, but will be canceled during the final assembly, demanded to the customer. in the technical manual is indicated as the assembler must behave towards this possible risk.

Now I'm a devil's lawyer. Is your supply almost a machine because it responds to the definition, or is it a non-compliant machine and requires other protection?

the verification of reply was commissioned by the client to an external study that deals exclusively with machine directive. the experts have read the manuals, taken view of the artifact and released favourable opinion.

 

[Fulvio Romano]

almost-machine with "on view" dense wheels in a compartment accessible from the opposite sides. one side is closed by a grate "normally" the other not.

the reason is that the almost-machine must be integrated into the line, by fitting it a structure that will make inaccessible the side left uncovered.

in this case you are deferring to the integrator the octemperation of res not belonging to the set "to which I can not comply", but of the set "to which it is not necessary to comply".

if you read my previous answers I criticized the expression:

because with the almost-machine I decide which to respect and which not

which means a wider freedom to decide not to respect a res.
For example, why did the other grate put it? Couldn't you have avoided her by telling the integrator to protect on both sides? No, and that's what I meant.

 

[pollo]

bho, I did only the lawyer and not the judge, I cannot express myself on this.
It's just that too many times I see machines that become qm just because I have to integrate them with others together.

 

[Fulvio Romano]

It's just that too many times I see machines that become qm just because I have to integrate them with others together.

I've seen a lot of them. It's a mistake. I'm serious. almost a car is almost a car, a car is a car. If I have a car I have to put in another car, the first will always remain a car, it can not become almost a car.
Unfortunately, in industrial practice we see all kinds of pigs and I think the problem is the concept of self-certification. every manufacturer interprets the norms in its own way, often without ever having read the norm but only through rumors of corridor that repeated thousand times become reality. errors, made self-referential, become modus operandi. without participating in transversal workshops certain wrong convictions are rooted and become practice until we escape the injury and all the altars are brought to light.

I don't say self-certification is a mistake. the world of machines is so heterogeneous both in terms of arguments, both in terms of size (both product and company) that is fine. But the culture of safety should be built with moments of confrontation that are very rarely promoted.

 

[pollo]

I begin to make a different opinion: we technicians are used not to interpret, but to apply.
if I apply I have two advantages:
1. houses stand up, machines work for the project period, etc. I can obviously make mistakes, but that's not what we're talking about.
2. If it doesn't work, I can still keep looking in the mirror because I applied the norm (directive, technical norm, law that is), and maybe on the side of cheese, "in science and conscience".
However, since they are laws, manufacturers call lawyers (they understand us, not us engineers), who, beyond the jokes in American style, do not apply but by nature they interpret (in light of..., in consideration of..., tqp, etc.). and since there is a general form of cowardice with regard to responsibilities, we seek the escape to demand others their own.
I do not think that we can talk about culture of security, or civic sense in general, if before we do not realize that anything we do is our responsibility.
excuse the vent, but just yesterday I saw a complex machine (of what we would normally call plant), with a well defined use destination, which receives material from other machines and provides its products to others (some directly, others through movements with wagons). the manufacturer has given the declaration all.iib because it enters to be part of a more complex set.

 

[exxon]

instead we make meetings with customers and decide "who cares about what". the almost machine will have these safety, while this other one is developed in the complete machine.

present designers, security managers and possibly third-party consultants.

What matters is that the finished machine is safe and normal.

no boat, no cheating.