Re: [PSES] Partly Completed Machinery...or not???

2016-04-15 Thread Crane, Lauren 
It strikes me that the term alone "sheave block" or "pulley" is not definitive 
with regard to whether the MD applies. It is the intended use and somewhat the 
functional limits imposed by the shape that is important for the decision.

A pulley with mounting holes, even if it has a moving axel included, such as  
http://g02.a.alicdn.com/kf/HTB1V2jhKXX8XpXXq6xXFXXXQ/2-5-inch-font-b-U-b-font-font-b-groove-b-font-font-b-pulley.jpg
is likely only useful as a component - and should not be considered 
individually in scope of the machinery directive.

However, a block pulley that is clearly intended to be part of the random 
rigging equipment someone might have laying around in a tool box on a job site 
to construct lifting rigging as needed such as
http://www.harkenindustrial.com/product/utility-snatch/
is more properly a stand alone machine and should be CE marked for the MD.

Lauren Crane
KLA-Tencor

From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: Friday, April 15, 2016 9:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???

UK's HSE has several guidance documents related to lifting operations and 
lifting equipment regulations that frustratingly do not specifically address 
pulleys or sheaves.

Ref http://www.hse.gov.uk/work-equipment-machinery/loler.htm

The site I posted earlier with a ce marked pulley was providing it in the 
context of the PPE directive.


Lauren Crane
KLA-Tencor

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Re: [PSES] Partly Completed Machinery...or not???

2016-04-15 Thread Crane, Lauren 
UK's HSE has several guidance documents related to lifting operations and 
lifting equipment regulations that frustratingly do not specifically address 
pulleys or sheaves.

Ref http://www.hse.gov.uk/work-equipment-machinery/loler.htm

The site I posted earlier with a ce marked pulley was providing it in the 
context of the PPE directive.


Lauren Crane
KLA-Tencor


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Re: [PSES] Partly Completed Machinery...or not???

2016-04-15 Thread John Allen 
Hi everyone,


Thank you all for your input, it is greatly appreciated!!


I hope to see everyone in LA next month.


John



From: John Woodgate 
Sent: Friday, April 15, 2016 2:08 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???


Yes, this is an important distinction. A pulley is just a wheel with a grooved 
rim and cannot be used by itself except for trivial or humorous purposes (e.g. 
coffee cup stand). A shave block is a pulley mounted on an axle in a frame and 
the frame may have an 'eye' at one or both ends, and maybe a hook as well. We 
already know there is a ratchet, so there is a pawl. That means two moving 
parts at least, the pulley rotates on the axle and the ratchet rotates on its 
pivot.



From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: Thursday, April 14, 2016 9:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???



John,



I suspect what you are dealing with is actually a sheave block, not a 'pulley' 
as mentioned in the extract from the guide quoted by Steve.



This being the case, it's not a lifting accessory because a lifting accessory 
is intended to go between the load and a piece of lifting machinery. It is 
however "an assembly of linked parts or components, at least one of which moves 
and which are joined together, intended for lifting loads and whose only power 
source is directly applied human effort" so it's a machine within the meaning 
of the Directive.



Regards



Nick.









On 14 Apr 2016, at 21:06, John Allen 
mailto:jral...@productsafetyinc.com>> wrote:



Thanks guys, but still struggling agreeing with the fact it's not part of the 
machinery directive.  A rope can be but a pulley block is not??



Steve - the last part of the first sentence is  that do not have a specific 
application and that are intended to be incorporated into machinery.  The 
pulley block is being sold by itself and has an application.



Also, is it not a lifting accessory??







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Re: [PSES] Partly Completed Machinery...or not???

2016-04-15 Thread John Woodgate 
Yes, this is an important distinction. A pulley is just a wheel with a
grooved rim and cannot be used by itself except for trivial or humorous
purposes (e.g. coffee cup stand). A shave block is a pulley mounted on an
axle in a frame and the frame may have an 'eye' at one or both ends, and
maybe a hook as well. We already know there is a ratchet, so there is a
pawl. That means two moving parts at least, the pulley rotates on the axle
and the ratchet rotates on its pivot.
 
From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: Thursday, April 14, 2016 9:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???
 
John,
 
I suspect what you are dealing with is actually a sheave block, not a
'pulley' as mentioned in the extract from the guide quoted by Steve. 
 
This being the case, it's not a lifting accessory because a lifting
accessory is intended to go between the load and a piece of lifting
machinery. It is however "an assembly of linked parts or components, at
least one of which moves and which are joined together, intended for lifting
loads and whose only power source is directly applied human effort" so it's
a machine within the meaning of the Directive. 
 
Regards
 
Nick. 
 
 
 
 
On 14 Apr 2016, at 21:06, John Allen mailto:jral...@productsafetyinc.com> > wrote:
 
Thanks guys, but still struggling agreeing with the fact it's not part of
the machinery directive.  A rope can be but a pulley block is not??
 
Steve - the last part of the first sentence is  that do not have a specific
application and that are intended to be incorporated into machinery.  The
pulley block is being sold by itself and has an application.
 
Also, is it not a lifting accessory??
 
 
 
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Re: [PSES] Partly Completed Machinery...or not???

2016-04-14 Thread Steven Brody 
John,

 

If the rope is specifically sold for use in lifting, and is not intended for
any other use, nor is it intended to be cut to length by the user,  then the
rope is within the scope of the MD.  These are covered in Recital 44 of the
Application Guide.

 

Recital 34 of the Guide refers to 'Pulleys, drums, wheels, ropes and chains'
and it says that 4.1.2.4 of Annex I of the Directive.  This section concerns
itself with the pulley (or drum or wheel) and rope (or chain ) and their
compatibility to ensure safe use.  The implication is that the pulley AND
the rope are in themselves a system and so the manufacturer must ensure that
the rope diameter is specified so there is no chance for it to come off the
pulley, that the groove in the pulley properly sized for the rope to sit
properly, etc.

 

Therefore, compliance to the MD is incumbent upon whoever manufactures the
device that the pulley is used in, and not the pulley manufacturer.

 

Steve Brody

sgbr...@comcast.net

Product EHS Consulting LLC

 

From: John Allen [mailto:jral...@productsafetyinc.com] 
Sent: Thursday, April 14, 2016 4:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???

 

Thanks guys, but still struggling agreeing with the fact it's not part of
the machinery directive.  A rope can be but a pulley block is not??

 

Steve - the last part of the first sentence is  that do not have a specific
application and that are intended to be incorporated into machinery.  The
pulley block is being sold by itself and has an application.

 

Also, is it not a lifting accessory??

 

This Directive applies to the following products:


(a)

machinery;

 


(b)

interchangeable equipment;

 


(c)

safety components;

 


(d)

lifting accessories;

 


(e)

chains, ropes and webbing;

 


(f)

removable mechanical transmission devices;

 


(g)

partly completed machinery.

 


d)

'lifting accessory' means a component or equipment not attached to the
lifting machinery, allowing the load to be held, which is placed between the
machinery and the load or on the load itself, or which is intended to
constitute an integral part of the load and which is independently placed on
the market; slings and their components are also regarded as lifting
accessories;

 


(e)

'chains, ropes and webbing' means chains, ropes and webbing designed and
constructed for lifting purposes as part of lifting machinery or lifting
accessories;

 

 

 

 

 

  _  

From: Steven Brody 
Sent: Thursday, April 14, 2016 2:13 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Partly Completed Machinery...or not??? 

 

John,

 

In the EU Application Guide 2006-42-ec, 2nd Edition, Recital 35, which is in
reference to and an explanation of the first indent of Article2(a), of the
Directive says:

The Machinery Directive does not apply as such to separate machinery
components such as, for example seals, ball-bearings, pulleys, elastic
couplings, solenoid valves, hydraulic cylinders, flange-connected gearboxes
and the like, that do not have a specific application and that are intended
to be incorporated into machinery. The complete machinery incorporating such
components must comply with the relevant essential health and safety
requirements. The machinery manufacturer must therefore choose components
with adequate specifications and characteristics.

 

So the product under discussion is clearly not within the scope of the
Machinery Directive.  

 

Doug Nix was correct when he said you need to read the Directive's scope.
If you need a copy of the Application Guide it is available online or
contact me privately and I will send it to you.

 

Thanks,

 

Steve Brody

sgbr...@comcast.net

Product EHS Consulting LLC

 

From: John Allen [mailto:jral...@productsafetyinc.com] 
Sent: Wednesday, April 13, 2016 6:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???

 

Thanks Dave.  

 

The product is sold to the end user without the rope.  The rope is the only
missing element.  The rope is specified as Max Working Load, Max Diameter
and Min Rope Break Load.

 

In some instances they do sell to integrators, etc.  In that case I can see
why it's considered Partly Completed Machinery.  Thank you!

 

 

 

  _  

From: Nyffenegger, Dave 
Sent: Wednesday, April 13, 2016 5:15 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Partly Completed Machinery...or not??? 

 

Well for sure Partly Completed machinery is not to bear the CE mark and is
to have a Declaration of Incorporation.  I think that is made clear in the
Blue Guide as well.   The question is if your product qualifies as Partly
Completed Machinery.

 

Is the end user expected to supply the rope, is the rope the only missing
element?  Is the product sold to the end user?  If so, then I would think
the product is not partly completed machinery.

 

Or is the produc

Re: [PSES] Partly Completed Machinery...or not???

2016-04-14 Thread Nick Williams 
John,

I suspect what you are dealing with is actually a sheave block, not a ‘pulley' 
as mentioned in the extract from the guide quoted by Steve. 

This being the case, it’s not a lifting accessory because a lifting accessory 
is intended to go between the load and a piece of lifting machinery. It is 
however “an assembly of linked parts or components, at least one of which moves 
and which are joined together, intended for lifting loads and whose only power 
source is directly applied human effort” so it’s a machine within the meaning 
of the Directive. 

Regards

Nick. 




> On 14 Apr 2016, at 21:06, John Allen  wrote:
> 
> Thanks guys, but still struggling agreeing with the fact it's not part of the 
> machinery directive.  A rope can be but a pulley block is not??
> 
> Steve - the last part of the first sentence is  that do not have a specific 
> application and that are intended to be incorporated into machinery.  The 
> pulley block is being sold by itself and has an application.
> 
> Also, is it not a lifting accessory??
> 
> 


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Re: [PSES] Partly Completed Machinery...or not???

2016-04-14 Thread Crane, Lauren 
John,

I am inclined to agree with you - that a pulley can/should be CE marked as 
lifting equipment, though I can't quite connect the dots.

I do see many adverts for CE marked pulleys using EN 13157 and citing the MD.
e.g., http://www.harkenindustrial.com/product/ce-pulleys/

Lauren Crane
KLA-Tencor

From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Thursday, April 14, 2016 3:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???


Thanks guys, but still struggling agreeing with the fact it's not part of the 
machinery directive.  A rope can be but a pulley block is not??



Steve - the last part of the first sentence is  that do not have a specific 
application and that are intended to be incorporated into machinery.  The 
pulley block is being sold by itself and has an application.



Also, is it not a lifting accessory??



This Directive applies to the following products:

(a)


machinery;




(b)


interchangeable equipment;




(c)


safety components;




(d)


lifting accessories;




(e)


chains, ropes and webbing;




(f)


removable mechanical transmission devices;




(g)


partly completed machinery.




d)


'lifting accessory' means a component or equipment not attached to the lifting 
machinery, allowing the load to be held, which is placed between the machinery 
and the load or on the load itself, or which is intended to constitute an 
integral part of the load and which is independently placed on the market; 
slings and their components are also regarded as lifting accessories;




(e)


'chains, ropes and webbing' means chains, ropes and webbing designed and 
constructed for lifting purposes as part of lifting machinery or lifting 
accessories;










From: Steven Brody mailto:sgbr...@comcast.net>>
Sent: Thursday, April 14, 2016 2:13 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] Partly Completed Machinery...or not???


John,



In the EU Application Guide 2006-42-ec, 2nd Edition, Recital 35, which is in 
reference to and an explanation of the first indent of Article2(a), of the 
Directive says:

The Machinery Directive does not apply as such to separate machinery components 
such as, for example seals, ball-bearings, pulleys, elastic couplings, solenoid 
valves, hydraulic cylinders, flange-connected gearboxes and the like, that do 
not have a specific application and that are intended to be incorporated into 
machinery. The complete machinery incorporating such components must comply 
with the relevant essential health and safety requirements. The machinery 
manufacturer must therefore choose components with adequate specifications and 
characteristics.



So the product under discussion is clearly not within the scope of the 
Machinery Directive.



Doug Nix was correct when he said you need to read the Directive's scope.  If 
you need a copy of the Application Guide it is available online or contact me 
privately and I will send it to you.



Thanks,



Steve Brody

sgbr...@comcast.net<mailto:sgbr...@comcast.net>

Product EHS Consulting LLC



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Wednesday, April 13, 2016 6:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Partly Completed Machinery...or not???



Thanks Dave.



The product is sold to the end user without the rope.  The rope is the only 
missing element.  The rope is specified as Max Working Load, Max Diameter and 
Min Rope Break Load.



In some instances they do sell to integrators, etc.  In that case I can see why 
it's considered Partly Completed Machinery.  Thank you!









From: Nyffenegger, Dave 
mailto:dave.nyffeneg...@bhemail.com>>
Sent: Wednesday, April 13, 2016 5:15 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: Partly Completed Machinery...or not???



Well for sure Partly Completed machinery is not to bear the CE mark and is to 
have a Declaration of Incorporation.  I think that is made clear in the Blue 
Guide as well.   The question is if your product qualifies as Partly Completed 
Machinery.



Is the end user expected to supply the rope, is the rope the only missing 
element?  Is the product sold to the end user?  If so, then I would think the 
product is not partly completed machinery.



Or is the product really not useable as is and intended to be incorporated into 
a larger machine by another manufacturer or integrator?



-Dave



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Wednesday, April 13, 2016 6:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Partly Completed Machinery...or not???



Hi guys,



I'm hoping to feedback and clarification if I'm reading the Machinery Direc

Re: [PSES] Partly Completed Machinery...or not???

2016-04-14 Thread John Allen 
Thanks guys, but still struggling agreeing with the fact it's not part of the 
machinery directive.  A rope can be but a pulley block is not??


Steve - the last part of the first sentence is  that do not have a specific 
application and that are intended to be incorporated into machinery.  The 
pulley block is being sold by itself and has an application.


Also, is it not a lifting accessory??


This Directive applies to the following products:

(a)


machinery;


(b)


interchangeable equipment;


(c)


safety components;


(d)


lifting accessories;


(e)


chains, ropes and webbing;


(f)


removable mechanical transmission devices;


(g)


partly completed machinery.



d)


‘lifting accessory’ means a component or equipment not attached to the lifting 
machinery, allowing the load to be held, which is placed between the machinery 
and the load or on the load itself, or which is intended to constitute an 
integral part of the load and which is independently placed on the market; 
slings and their components are also regarded as lifting accessories;


(e)


‘chains, ropes and webbing’ means chains, ropes and webbing designed and 
constructed for lifting purposes as part of lifting machinery or lifting 
accessories;











From: Steven Brody 
Sent: Thursday, April 14, 2016 2:13 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Partly Completed Machinery...or not???


John,



In the EU Application Guide 2006-42-ec, 2nd Edition, Recital 35, which is in 
reference to and an explanation of the first indent of Article2(a), of the 
Directive says:

The Machinery Directive does not apply as such to separate machinery components 
such as, for example seals, ball-bearings, pulleys, elastic couplings, solenoid 
valves, hydraulic cylinders, flange-connected gearboxes and the like, that do 
not have a specific application and that are intended to be incorporated into 
machinery. The complete machinery incorporating such components must comply 
with the relevant essential health and safety requirements. The machinery 
manufacturer must therefore choose components with adequate specifications and 
characteristics.



So the product under discussion is clearly not within the scope of the 
Machinery Directive.



Doug Nix was correct when he said you need to read the Directive’s scope.  If 
you need a copy of the Application Guide it is available online or contact me 
privately and I will send it to you.



Thanks,



Steve Brody

sgbr...@comcast.net<mailto:sgbr...@comcast.net>

Product EHS Consulting LLC



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Wednesday, April 13, 2016 6:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???



Thanks Dave.



The product is sold to the end user without the rope.  The rope is the only 
missing element.  The rope is specified as Max Working Load, Max Diameter and 
Min Rope Break Load.



In some instances they do sell to integrators, etc.  In that case I can see why 
it's considered Partly Completed Machinery.  Thank you!









From: Nyffenegger, Dave 
mailto:dave.nyffeneg...@bhemail.com>>
Sent: Wednesday, April 13, 2016 5:15 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: Partly Completed Machinery...or not???



Well for sure Partly Completed machinery is not to bear the CE mark and is to 
have a Declaration of Incorporation.  I think that is made clear in the Blue 
Guide as well.   The question is if your product qualifies as Partly Completed 
Machinery.



Is the end user expected to supply the rope, is the rope the only missing 
element?  Is the product sold to the end user?  If so, then I would think the 
product is not partly completed machinery.



Or is the product really not useable as is and intended to be incorporated into 
a larger machine by another manufacturer or integrator?



-Dave



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Wednesday, April 13, 2016 6:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Partly Completed Machinery...or not???



Hi guys,



I'm hoping to feedback and clarification if I'm reading the Machinery Directive 
correctly.



The product is a Pulley Block with a brake/ratchet mechanism.  It is not 
supplied with the rope.  It is used for lifting machinery, not people.



We believe this to be partly completed machinery and should not bear the CE 
mark and be supplied with a Declaration of Incorporation.  We have heard 
different opinions and some believe because it has a brake/ratchet it should be 
marked CE and supplied with a Declaration of Conformity.



Your thoughts and opinions would be appreciated.



Best Regards,



John

-


This message is from the IEEE Product Safety Engin

Re: [PSES] Partly Completed Machinery...or not???

2016-04-14 Thread Steven Brody 
John,

 

In the EU Application Guide 2006-42-ec, 2nd Edition, Recital 35, which is in
reference to and an explanation of the first indent of Article2(a), of the
Directive says:

The Machinery Directive does not apply as such to separate machinery
components such as, for example seals, ball-bearings, pulleys, elastic
couplings, solenoid valves, hydraulic cylinders, flange-connected gearboxes
and the like, that do not have a specific application and that are intended
to be incorporated into machinery. The complete machinery incorporating such
components must comply with the relevant essential health and safety
requirements. The machinery manufacturer must therefore choose components
with adequate specifications and characteristics.

 

So the product under discussion is clearly not within the scope of the
Machinery Directive.  

 

Doug Nix was correct when he said you need to read the Directive's scope.
If you need a copy of the Application Guide it is available online or
contact me privately and I will send it to you.

 

Thanks,

 

Steve Brody

sgbr...@comcast.net

Product EHS Consulting LLC

 

From: John Allen [mailto:jral...@productsafetyinc.com] 
Sent: Wednesday, April 13, 2016 6:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Partly Completed Machinery...or not???

 

Thanks Dave.  

 

The product is sold to the end user without the rope.  The rope is the only
missing element.  The rope is specified as Max Working Load, Max Diameter
and Min Rope Break Load.

 

In some instances they do sell to integrators, etc.  In that case I can see
why it's considered Partly Completed Machinery.  Thank you!

 

 

 

  _  

From: Nyffenegger, Dave 
Sent: Wednesday, April 13, 2016 5:15 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Partly Completed Machinery...or not??? 

 

Well for sure Partly Completed machinery is not to bear the CE mark and is
to have a Declaration of Incorporation.  I think that is made clear in the
Blue Guide as well.   The question is if your product qualifies as Partly
Completed Machinery.

 

Is the end user expected to supply the rope, is the rope the only missing
element?  Is the product sold to the end user?  If so, then I would think
the product is not partly completed machinery.

 

Or is the product really not useable as is and intended to be incorporated
into a larger machine by another manufacturer or integrator?

 

-Dave

 

From: John Allen [mailto:jral...@productsafetyinc.com] 
Sent: Wednesday, April 13, 2016 6:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Partly Completed Machinery...or not???

 

Hi guys, 

 

I'm hoping to feedback and clarification if I'm reading the Machinery
Directive correctly.

 

The product is a Pulley Block with a brake/ratchet mechanism.  It is not
supplied with the rope.  It is used for lifting machinery, not people.

 

We believe this to be partly completed machinery and should not bear the CE
mark and be supplied with a Declaration of Incorporation.  We have heard
different opinions and some believe because it has a brake/ratchet it should
be marked CE and supplied with a Declaration of Conformity.

 

Your thoughts and opinions would be appreciated.

 

Best Regards,

 

John

-


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-


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Re: [PSES] Partly Completed Machinery...or not???

2016-04-13 Thread IEEE 
John,

Go back to the Scope. The pulley block does not meet the definition for a 
machine. A pulley block on it’s own does not qualify as a machine since it does 
not have a power source or a control system. It is a machine part, like a 
gearbox or a driveshaft.

Doug Nix
d...@ieee.org
+1 (519) 729-5704

> On Apr 13, 2016, at 18:05, John Allen  wrote:
> 
> Hi guys, 
> 
> I'm hoping to feedback and clarification if I'm reading the Machinery 
> Directive correctly.
> 
> The product is a Pulley Block with a brake/ratchet mechanism.  It is not 
> supplied with the rope.  It is used for lifting machinery, not people.
> 
> We believe this to be partly completed machinery and should not bear the CE 
> mark and be supplied with a Declaration of Incorporation.  We have heard 
> different opinions and some believe because it has a brake/ratchet it should 
> be marked CE and supplied with a Declaration of Conformity.
> 
> Your thoughts and opinions would be appreciated.
> 
> Best Regards,
> 
> John
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
> discussion list. To post a message to the list, send your e-mail to 
> mailto:emc-p...@ieee.org>>
> All emc-pstc postings are archived and searchable on the web 
> at:http://www.ieee-pses.org/emc-pstc.html 
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at 
> http://product-compliance.oc.ieee.org/ 
>  can be used for graphics (in 
> well-used formats), large files, etc.
> Website:  http://www.ieee-pses.org/ 
> Instructions:  http://www.ieee-pses.org/list.html (including how to 
> unsubscribe) 
> List rules:  http://www.ieee-pses.org/listrules.html 
> 
> For help, send mail to the list administrators:
> Scott Douglas mailto:sdoug...@ieee.org>>
> Mike Cantwell mailto:mcantw...@ieee.org>>
> For policy questions, send mail to:
> Jim Bacher mailto:j.bac...@ieee.org>>
> David Heald mailto:dhe...@gmail.com>>


-

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discussion list. To post a message to the list, send your e-mail to 


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formats), large files, etc.

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Mike Cantwell 

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Re: [PSES] Partly Completed Machinery...or not???

2016-04-13 Thread John Allen 
Thanks Dave.


The product is sold to the end user without the rope.  The rope is the only 
missing element.  The rope is specified as Max Working Load, Max Diameter and 
Min Rope Break Load.


In some instances they do sell to integrators, etc.  In that case I can see why 
it's considered Partly Completed Machinery.  Thank you!






From: Nyffenegger, Dave 
Sent: Wednesday, April 13, 2016 5:15 PM
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Partly Completed Machinery...or not???


Well for sure Partly Completed machinery is not to bear the CE mark and is to 
have a Declaration of Incorporation.  I think that is made clear in the Blue 
Guide as well.   The question is if your product qualifies as Partly Completed 
Machinery.



Is the end user expected to supply the rope, is the rope the only missing 
element?  Is the product sold to the end user?  If so, then I would think the 
product is not partly completed machinery.



Or is the product really not useable as is and intended to be incorporated into 
a larger machine by another manufacturer or integrator?



-Dave



From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Wednesday, April 13, 2016 6:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Partly Completed Machinery...or not???



Hi guys,



I'm hoping to feedback and clarification if I'm reading the Machinery Directive 
correctly.



The product is a Pulley Block with a brake/ratchet mechanism.  It is not 
supplied with the rope.  It is used for lifting machinery, not people.



We believe this to be partly completed machinery and should not bear the CE 
mark and be supplied with a Declaration of Incorporation.  We have heard 
different opinions and some believe because it has a brake/ratchet it should be 
marked CE and supplied with a Declaration of Conformity.



Your thoughts and opinions would be appreciated.



Best Regards,



John

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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Mike Cantwell mailto:mcantw...@ieee.org>>

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Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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Mike Cantwell 

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David Heald:

Re: [PSES] Partly Completed Machinery...or not???

2016-04-13 Thread Nick Williams 
The deciding factor is whether the manufacturer has control of compliance with 
all of the applicable EHSRs and, by extension, whether it is expected that the 
product will under go a further conformity assessment procedure before it is 
placed on the market or put into service. If, and only if, the answer to the 
first question is ‘no’ and to the second question is ‘yes’ then the Declaration 
of Incorporation route is correct. If the answer to either question is the 
reverse then compliance with the applicable EHSRs is the responsibility of the 
manufacturer and the product must be CE marked and have a Declaration of 
Conformity. 

It’s important to realise that ‘control of compliance with the EHSRs’ may just 
mean that the manufacturer describes the relevant protections in their 
installation instructions. For example, if the product is a machine tool which 
is supplied without complete guarding because it is going to be incorporated 
with other machinery into a manufacturing cell, the manufacturer is still able 
to describe the guarding requirements within their documentation and hence has 
control of that EHSR even if they don’t provide the hardware which forms the 
protection. Thus, the machine must be CE marked, even if the guards are 
supplied by someone else. 

Nick. 


> On 13 Apr 2016, at 23:05, John Allen  wrote:
> 
> Hi guys, 
> 
> I'm hoping to feedback and clarification if I'm reading the Machinery 
> Directive correctly.
> 
> The product is a Pulley Block with a brake/ratchet mechanism.  It is not 
> supplied with the rope.  It is used for lifting machinery, not people.
> 
> We believe this to be partly completed machinery and should not bear the CE 
> mark and be supplied with a Declaration of Incorporation.  We have heard 
> different opinions and some believe because it has a brake/ratchet it should 
> be marked CE and supplied with a Declaration of Conformity.
> 
> Your thoughts and opinions would be appreciated.
> 
> Best Regards,
> 
> John


-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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Re: [PSES] Partly Completed Machinery...or not???

2016-04-13 Thread Nyffenegger, Dave 
Well for sure Partly Completed machinery is not to bear the CE mark and is to 
have a Declaration of Incorporation.  I think that is made clear in the Blue 
Guide as well.   The question is if your product qualifies as Partly Completed 
Machinery.

Is the end user expected to supply the rope, is the rope the only missing 
element?  Is the product sold to the end user?  If so, then I would think the 
product is not partly completed machinery.

Or is the product really not useable as is and intended to be incorporated into 
a larger machine by another manufacturer or integrator?

-Dave

From: John Allen [mailto:jral...@productsafetyinc.com]
Sent: Wednesday, April 13, 2016 6:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Partly Completed Machinery...or not???


Hi guys,



I'm hoping to feedback and clarification if I'm reading the Machinery Directive 
correctly.



The product is a Pulley Block with a brake/ratchet mechanism.  It is not 
supplied with the rope.  It is used for lifting machinery, not people.



We believe this to be partly completed machinery and should not bear the CE 
mark and be supplied with a Declaration of Incorporation.  We have heard 
different opinions and some believe because it has a brake/ratchet it should be 
marked CE and supplied with a Declaration of Conformity.



Your thoughts and opinions would be appreciated.



Best Regards,



John
-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website: http://www.ieee-pses.org/
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David Heald mailto:dhe...@gmail.com>>

-

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All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald:

[PSES] Partly Completed Machinery...or not???

2016-04-13 Thread John Allen 
Hi guys,


I'm hoping to feedback and clarification if I'm reading the Machinery Directive 
correctly.


The product is a Pulley Block with a brake/ratchet mechanism.  It is not 
supplied with the rope.  It is used for lifting machinery, not people.


We believe this to be partly completed machinery and should not bear the CE 
mark and be supplied with a Declaration of Incorporation.  We have heard 
different opinions and some believe because it has a brake/ratchet it should be 
marked CE and supplied with a Declaration of Conformity.


Your thoughts and opinions would be appreciated.


Best Regards,


John

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: