declaration by fessuratrice

[Giacomo Lepore]

Good morning.
I'm treating the iter ce of a cracker, i.e. a machine with four heads making cutters on a pvc tube. serves to crack the tubes used for example for suction.

It's a closed machine, with an automatic trolley carrying the tube in place, locks it, the four heads approach, cut it and draw. then the pipe is expelled.

This type of machine is normally counted among the milling machines, but in reality the heads carry blades. I therefore have the doubt that it may fall in Annex I, point 4.3 for example.

What do you think? Do you have such machine experience or do you have a declaration of conformity? Is there a standard of type c dealing with these machines?

Thank you very much

 

[gerod]

Hi.
I think we're talking about point 4:

4 belt saws and/or manual unloading for wood and materials processing with similar physical characteristics or for processing meat and materials with similar physical characteristics, of the following types:
4.1 blade saws(s) in fixed position during cutting, with table or support of the fixed or alternating piece; 4.2 blade saws(s) mounted on an alternating motion trolley.

the "plastic" is among the "like materials" to the wood that are mentioned in the first points of the annex iv:
we see the comment § 388 of the guideline to the Machinery Directive, edition 2.3:

item 1 covers only circular saws for working with wood and analogous materials or for working with meat or analogous materials belonging to the categories referred to in items 1.1 to 1.4.
it should also be noted that not all circular saws for working wood are concerned; for example, sawing machinery with a blade moved by hand during cutting (such as some mitre saws) are not referred to in annex iv.
materials analogous to wood include, for example, chipboard, fibreboard, plywood (and also these materials when they are covered with plastic or light alloy laminates/edges), cork, bone, rigid rubber or plastic.

the guide explains what it means by manual loading and unloading machines or because more dangerous, given the most important involvement of the operator near the tool (lama or fresa, indifferent in this case):

items 1.3, 1.4, 3 and 4 refer to manual loading and/or unloading. manual loading and/or unloading occurs when the operator places workpieces directly in the feed device or workpiece support device and removes them directly from that device, so that it is possible for the operator to have direct contact with the workpiece while it is in contact with the tool. machinery is not considered to have manual loading or unloading if it is equipped with a feed device or a device for loading and unloading workpieces (such as, for example, a conveyor) such that the tools are out of reach of the user while the device is being used and the machinery cannot be operated without the device.

for the philosophy indicated by the norm, this does not fall within the first 8 points since there is a kind of magazine that brings the piece to the tools.
I do not think there is a specific norm, but since plastic is similar to wood, it applies the rules on circular saws for similarities.
Hi.
ps. thanks to my fellow manuel for the analysis!

 

[Giacomo Lepore]

thank you so much gerod, and thanks also manuel (which I do not have the pleasure to know) for the excellent and exhaustive analysis!