experimental machine

[Giacomo Lepore]

Good evening,
I would like to ask a few questions about the machinery directive on which I am not very careful:

1) if I have an experimental machine, prototypal, and I would like to make it work supervised, but without being able to mark it because maybe it is far from its definitive configuration, how should I behave?

2) Are there rules or directives regarding the emergency sequences that must have a plant, and on the redundancy of the actuators involved in such sequences, if any malfunction can cause damage, but does not involve risk to people?

3) if I design a machine, but I only realize it in part, asking my client to realize some parts on my design, how do I proceed to the full machine marking? Is there a problem? For example, if I build a lift mounted on a motorized trolley, and the motorized trolley is built by the customer on my design, if in the technical dossier I describe everything, there are contraindications on the fact that the construction is not all made by me?

They look like stupid questions, but a client made me contests, and I don't understand who the two are wrong...

thanks to anyone who can help me...maybe with some reference to the current legislation. . .

 

[meccanicamg]

Good evening, Jacob,
then in reference to the machinery directive 2006/42/ce it is said that:
This Directive applies to the following products:
a) machines;
b) interchangeable equipment;
c) safety components;
d) lifting accessories;
e) chains, ropes and straps;
f) removable mechanical transmission devices;
g) almost-machine.

are excluded from the scope of this
Directive:
...
h) specially designed and built machines for purposes of
research to be temporarily used in laboratories;so until you put it on the market and use it temporarily and experimentally it does not need.

emergency plants are regulated, both according to the machine directive and in specific regulations also of the electric industry (interlock, photoelectric barriers, do not put the emergency managed by plc, etc.)

for the certification of a machine consisting of your products and the customer you can proceed in two ways:

1) you assume all responsibility by signing the c and then declare that it was born and designed and assembled and tested by you and if there is any error of assembly construction etc that does not depend on you you stay in the middle like a chicken
2) make the declaration of incorporation by the third supplier of its product (if quasimacchiana) or declaration if (defined machine) and you still record the statement by attaching to us how much responsibility of the third supplier. you guarantee for everyone however signing the c but... for the incorporated part if it has defects you originally rival you on him.

so in flight is how much I think

 

[Giacomo Lepore]

h) specially designed and built machines for purposes of
research to be temporarily used in laboratories;

so if such machine must be used in plant and not in laboratory, is it not possible?
is trial on process industry. It is therefore not possible to transfer the process to the laboratory. . .

 

[meccanicamg]

so if such machine must be used in plant and not in laboratory, is it not possible?
is trial on process industry. It is therefore not possible to transfer the process to the laboratory. . .

If this is not possible, that is, you cannot keep circumscribed by production with the appropriate measures I would say that you need the c by force of things

 

[gerod]

answers.
1.
point h) is valid if you are in a lab, otherwise it is not applicable.
you may be part of the definition of trade fairs or demonstration machines:

§ 19 trade fairs and exhibitions
recital 17 introduces the provision that enables manufacturers to exhibit new models of machinery at trade fairs and exhibitions before the conformity of such products with the machinery directive has been assessed or to exhibit machinery with certain elements such as, for example, guards removed for demonstration purposes. in such cases, the exhibitor must display an appropriate sign and take adequate safety measures to protect persons from the risks presented by the exhibited machinery – see §108: comments on article 6 (3).

source: driving the machine directive.

2.
en 954/1 and en 13849-1

3.
I say machine yours with declaration of conformity; the client will then make the c of the plant.
your machine has its own use destination and can not be considered almost machine even if many manufacturers now do the tricks (see some manufacturer of conveyor belts, screws that declare these objects almost machines; I do not agree and have motivated my statements several times, even in this forum).

I call on you to read the guidelines of the new directive.
I am in English but they clarify a lot.
Hi.

 

[meccanicamg]

answers.
I call on you to read the guidelines of the new directive.
I am in English but they clarify a lot.
Hi.

in Italian there is the guide of federmacchine:http://www.certificomacchine.it/news_pick_allegato.php?id=104to read carefully. and anyway it is always good to have a c, sometimes it is very little enough to get it. I spit better: it is known that a working center with robot storage is a dangerous area. if you create an inaccessible fence to man, there is no projection of material etc. etc. the ce is valid.

However, there are hardly any trade fairs within the production department... bypassing the law seems so useless to me. I think it is more worth considering to build according to current regulations and to apply I am blessed there is not an infectious disease.

just follow the simplest and most restrictive rules. Spread a very simple manual. and make the car book. time bureaucracy 8 hours (to say so).

automating the writing of machine books and manuals could streamline the procedure there.

 

[Giacomo Lepore]

beautiful the guide of federmacchine, in which I read:

the machines specially designed and built for research purposes to be temporarily useful
in laboratories.
in many cases it is necessary that the manufacturer may use or try the machine, or its parts, during
the development, construction, assembly, installation, regulation and evaluation activities, before the immissio-
in the market or the final machine.
For example, in the case of large printing machines used for the production of newspapers, there is the need to
sità to install prototypes (usually at a potential customer) in order to try the machine, not finished,
in real conditions (such as the use of various types of paper quality, work in temperature and humidity conditions
the environment of destination, etc.). during these activities, performed on prototypes, pre-series or, in generation
i, on unfinished machines, the staff of the manufacturer is working with some protections (repair, doors,
etc.) or safety measures not yet implemented or active.
Directive 98/37/ce, as well as Directive 2006/42/ce, does not expressly apply to prototypes, prototypes,
pre-series and unfinished machines. These machines are, by definition, still under development
the manufacturing process is not yet finished (for example, the technical file is not
I would like to ask the Commission to take the necessary steps to ensure that the directive is implemented.
machines); machines at this stage are therefore not to be understood as “imposed on the market” or “messages
(k) of Directive 2006/42/ce.
the activities carried out (at the manufacturer or at the potential, customer) on prototypes, pre-series and macchi-
not finished as part of the process of development and manufacture of the machine should not involve
availability of the machine for the user. all measures must be taken during these activities.
necessary and adequate to ensure the protection of people. In addition, staff involved in these activities
It must be trained and properly supervised.

and this is in every detail exactly what I intend to do. What's wrong with me?
in practice this is a machine susceptible to be certified, but as it is a client expires... erm...very pignolo, it makes no sense to make a technical file for a machine that will ultimately be radically transformed. . .
of course throughout the commissioning we supervise, do the tests, then, reach the performances, the system would be frozen and certified as it is.

 

[meccanicamg]

as I told you: supercancellata anti-injury around, only one person responsible for manoeuvring/managing. I mean, put the restrictions. It's not there yet, but you can make it anti-$weep anyway.

 

[Giacomo Lepore]

It is not my intention to put into operation a dangerous thing. safety first, but not always safety and paperwork go in the same direction, I could make countless examples lived!

the speech is to do a sure thing, that works supervised, but that is susceptible to changes even substantial in progress. if I certify it and then change it, companyly it is a suicide, much better to complete the technical file when the situation is frozen. . Naturally if possible.

 

[meccanicamg]

It is not my intention to put into operation a dangerous thing. safety first, but not always safety and paperwork go in the same direction, I could make countless examples lived!

the speech is to do a sure thing, that works supervised, but that is susceptible to changes even substantial in progress. if I certify it and then change it, companyly it is a suicide, much better to complete the technical file when the situation is frozen. . Naturally if possible.

Of course. I think it is better to sign a contract where regulations are cited, etc. that is nothing but what we said here and let him sign from the parties. singing paper.

 

[gerod]

You'll end up doing it when it's frozen.
I remember that if I (constructor a) build a work platform that must be mounted on a cart, I will have to mark there the car even if it alone does not work. there is the destination of use.
then the builder b will make the ce of the platform + wagon.

Moreover, remember that the directive comes first, then the European guidelines, then the local ones and the opinions.

 

[meccanicamg]

You'll end up doing it when it's frozen.
I remember that if I (constructor a) build a work platform that must be mounted on a cart, I will have to mark there the car even if it alone does not work. there is the destination of use.
then the builder b will make the ce of the platform + wagon.

Moreover, remember that the directive comes first, then the European guidelines, then the local ones and the opinions.

if the use is identified you do the ce, otherwise you do the embedding certificate (ex Annex 2 b) for almost machines. However the final customer must make unquestionably the c of the plant both that it is formed by machines with c that without that almostmachines

 

[gerod]

almost machines are a hybrid that has created huge mess.
I agree with you about the use (it is said destination of use) identified but I remember that, for example, the cranes that must be mounted on truck are machines while before they were not (in this case they are machines because interchangeable equipment).
It is therefore necessary to understand clearly what definition of the directive is the subject, then it is decided.
there are builders who for the same object do ce, others say they are almost machines, other than they do absolutely nothing.

for reducers, for example, it has been decided that they are components without particular applications (Eurotrans decision quite questionable): Go around and see that:
- sew even brand them (machines)
- tramecs like almost machines (the beautiful thing about the declaration of incorporation of the tramec is that they list the observant res and put them all, even those of point 2 relating to the commands, etc. - they also have the emergency arrest, I do not know where, but the res says there is)

this to make you notice that confusion is general and very often builders are poorly advised. We must therefore read and understand the directive, guidelines, norms and then decide what to do.