Member postings for Robert Atkinson 2

Phil,
the statement " let me clarify, CE marking is exclusively for goods offered for sale in the EEA " is incorrect. CE compliance (not just the mark) applies (with a few specific exceptions) to items "put into use" not just sold.
An item does not need a mecanisim to require compliance.

What was the Item your brother made that could not be marked (just the class is enough)?

I do have a through undersanding of this, unlike some. I do not think CE marking is great, thee process an enforcement is flawed but the underlying technical requirements are good.

Robert G8RPI.

Edited By Robert Atkinson 2 on 06/04/2019 05:17:59

But if you have a valid Technical Construction File they can't do anything to you!

Paul,

The condition for a piece of machinery not being consiered put on the market you have to comply with (a) AND one or more of (i),(ii) or (iii) Hobby use doe not tick the box for (i),(ii) or (iii).
Unfortunatly there is one directive where you wrk in the shed can affect others without you knowing it, EMC. Your new CNC conversion could be cauing interference to all sorts of radio services including those with safety of life implications.

Robert G8RPI.

Cabinet Enforcer,
I don't want an argument, I want to learn, raise awareness of a possible issue and have a meaningfull discussion.
My personal opinion is that the letter of the regulations DOES apply fully to hobbists but in pratice if you keep it in he shed there will not be any issue apart from the posible problem with insurance in the case of a claim. If you follow good practice and gudance there is les chance of an issue.

Robert G8RPI.

Great find and explanation Bikepete.That is a new one for me, While as he says, it's not legal judgment it is official guidance and therefore a reasonable defence. In all but the very worst cases I'd be confident the enfocement agencies would back away fro any action other than a "don't do it again" warning when pointed to this document.

Robert G8RPI.

Hi Neil,

Do you have a reference for the "uniquely singular" exemption and which Directives it applies to? I'm not doubting you, but As I said at the begining proper references are good. I can't see how it would apply to the EMC Directive, but the EMC Directive does not apply to everthing.
Taking stepper motors, driver modules and a processor (PC or Arduino)and fitting them to an existing machine tool most certainly does need CE compliance. If the individual components were compliant and approved for that application and you correctly followed their instructions (instructions are a specfic requirement of most Directives but are missing from many items) then showing compliance could be as simple as making a statement.

Connecting a phone to different charger does not break any regulations unless the instructions for one othe other prohibits it e.g. "use only ACME approved charger" but like most compliance unless there is an issue (or someone doesn't like you and reports it) nothing will be done. People have been electrocuted by poor quality chargers and yes if you buy a dodgy charger, use it on a work phone / battery drill etc and get injured the company is responsble even though it was your charger. Yes it's seems silly but this is why most companies phohibit the use personal mains powered equipment at work.

Robert G8RPI.

I'm not sure what you mean by the first paragraph, can we have plain languge please?

On the second, I would not want to be the person who put the compliance spotlight on the hobby. I have my own opinion on this, based on professional involvement since the regulations were introduced. Yes I'm being deliberately controversial, but to raise awareness not be argumentative.

PUWER does not apply to hobbies becaue they are not work and have no employees. CE compliance is certainly a key requirement of PUWER, but CE applies to much more than work equipment.
Ignorance if the law is no defence and for something that most on here know litlle or nothing about, the EMC directive, the worst case consequence of non compliance, however unlikely, unlikely is causing an airliner to crash. No, it's not that far fetched, if you lived near an airport and your new project emitted on the local ILS frequency it could cause a crash if other holes in the cheese lined up (google James Reason cheese accident theory).

Robert G8RPI.

Ahh, you are ignoring the "and" in point a,

AND "it will not be put into service in an EEA state" put into service means using.

Conformance is not about making, selling or business use. The lathe you buy as a hobbyist has to conform to the same requirements as one used by business. Domestic appliances have to conform too. Selling is not a requirement, selling, marketing OR putting into use requires compliance otherwise you could give non compliant items away free with a token compliant ones.
It is true that you will only have an issue for home use if something goes wrong. Unfortunatly it's then too late.

Neil's approach is OK for the LVD but what about Machinery. EMC and Pressure directives?
Following good practice is the best defence agnst both incidents and their cnsequences.

Dave (SOD) said

"CE Marking is easy - you don't have to! and Privately adding a CE mark is illegal."

Do you have any references to back up these statements? I Did ask for references in my question. The CE regulations state that there must be compliance at offering for sale or at "first use". They say nothing about commercial production. What does "privately" mean? The responsibility for compliance is on the manufacturer or importer. If you manufacture or import it you can (must) put a CE mark on it (unless it is something like lifting equipment that needs certification by a Notified Body). By doing so you also take responsibility. There is no relief for on-off's or non commercial items. There used to be exemption in the LVD where you did not to have to mark an item that was for own use but you still had to ensure it conformed so not putting a sticker on was silly. This exception has been removed.
It's not retrospective so used items only have to conform to the standard applicable when new (and not in dangerous condition) if sold, unless they have been remnufactured or had significant modification.

I'm not sure why you think amateur radio is more dangerous than model engineering especially now most amateurs don't use valves or build their own equipment.

Robert G8RPI

Drives, including older 51/4" ones have other useful parts. The disk platters make good minature surface plates and the spacers between them, tubular paralells or gauge rings (but light alloy not steel) CD-ROM drives also have nice precision ground and polished rods in pairs that the optcal heads run on.

Robert G8RPI.

Drives, including older 51/4" ones have other useful parts. The disk platters make good minature surface plates and the spacers between them, tubular paralells or gauge rings (but light alloy not steel) CD-ROM drives also have nice precision ground and polished rods in pairs that the optcal heads run on.

Robert G8RPI.

First please don't mention the B word, assume equivelent level legislation whatever happens re EU membership.

The question is - where do model engineers stnd regarding CE compliance and marking? For this Forum it's the Machenery Directive, Low Voltage Directive and EMC directive. With the notable exception of the EMC directive and radio amateurs, none of these differentiate between commercial production and one-off or personal projects. Thus in theory if you build your own CNC mchine or convert a manul machine to CNC you have to comply with the directives. For any form of commercial production or use by employees non compliance is an offence.

I assume no one does this, but is anyone aware of any official guidance (references please not just opinions) releaving hobbyists?

Obviously if you DIY, keep it in the shed and nothing goes wrong the question is moot. What if somthing goes wrong or you sell (or give away) your one off? Unfortunatly things do go wrong. and we are now a litigous society with lawers happy to take on cases and insurance companies happy to use any reason not to pay out. Some senarios are:

You seriously injure yourself (or worse) and insurance doesn't pay out (more of an issue for those in work with dependents)

You sell or give away youe machine and the new owner is injured an they (or more likely their insurance co.) comes after you for compensation.

The machine catches fiire and burns down the shed/house/next door/ street

The Machine causes radio interference and OFCOM come knocking on your door.

I'm not suggesting anyone should stop building their own machines, but I think we should raise awareness of possible issues and encourage good practice in the machines we build. Unfortunatly I don't think things are going to get better and one incident with the wrong press coul have a big mpact on the hobby.

Robert G8RPI
(I'm involved in regulatory compliance as part of my day job)

As a private individual I can't see anything illegal as long as you own the cylinder, except possibly CE marking and test, but these are rarely if ever applied in practice to constructions by indidividuals. There are a couple of concerns though:
1/ if there is any propane remaining in the tank you could get a compression ignition explosion but you would have to fill it really fast.
2/ unless you are using dried air, condensate could cause corrosion and failure. Drain valve required.
3/ commonsense says fit an over pressuere device. I'd prefer one at 150PSI but the one built into the existing valve is better than nothing unless you have damaged or disabled it
4/ And this is a big one, if the worst should happen your insurance company(ies) may not pay out if they think you did not take due care or cted recklessly. This could have you losing your assets or your dependents not getting life insurance.

Robert G8RPI.

Helium is not suitable as a welding shield gas for at least three reasons.

1/ It's lighter than air so will float off (unless you are welding in an enclosed overhead postion)
2/ It's a very good conductor of heat so will cool the welds excessively (It's used in small sealed instrumenets to conduct heat away and low cost helium leack detectos usits conductivity to detect trace amounts)
3/ It's expensive.

Robert G8RPI.

Edited By Robert Atkinson 2 on 01/04/2019 16:16:17

Hi,
any lathe sold by a reputable UK supplier will run fine on 240V. The whole 220V / 230V / 240V thing is a standardisation kludge. Europe used to specify 220V with a +- tolerance, UK was 240V with a +- tolerence. To harnonise we agreed on 230V with a tolerance that encompassed both 220V and 240V. A lot of Far Eastern kit still lists 220V but modern electrical equipment is very tolerant of supply voltage. As a ex tool mker I'm sure you appreciate the tolerence thing.

Robert G8RPI

Edited By Robert Atkinson 2 on 30/03/2019 15:15:40

Motor capacitors are normally AC rated so take the peak voltage into account. a 270V AC capacitor will be fine on UK mains.

Are you sure the compressor has not seized? they normally run in an oil bath. Most Jun-Air silents have a band clamp on the housing so you can take the top off and make sure it's rurning by hand. The relay is also suspect..

Robert G8RPI.

OK,

This is probably "specmanship" the 3A , 11A or whatener i probly the no load or minimum load current and is given so you can "calculate" a long battery life. I'll bet anyone it closer to 100A when pulling a 180 person uphill.

Robert G8RPI.

Sorry, but there is no dot. The other dots and colons are square and clearly visible.
There are 3 leads on this motor the low current one you mentioned earlier is not the power connection, it's probably a temperature sensor.
This motor is much too big for 265W, it will be 950W output and 2650W electrical input. Peak efficency for a PMDC is adout 65% but that is at 10% load. at rated load it's likel to be 45%. This is a 4 brush motor which are less efficentso the 36% indicated by the data plate for max load is entirely reasonable. We hae no idea what the duty cycle is.

Robert G8RPI.

It's a 4 brush motor with a flat braided strap for connection, despite the spacing on the nameplate, that alone says it's 110A current rating not 11A. You can get speed controllers designed for robots that will handle this sort of current. Search for high current pwm motor speed control e.g. **LINK** (from search no idea if it's any good).
Unless doing sustained drilling a couple of 12V lead acid batteries and a intelligent charger would be easier than a 100A power supply.
Brushed DC motors do not loose torque with reduced speed. Torque is only limited by the available supply current and voltage, current rating of motor / supply and mechanical strength. Normally the winding resistance will limit the current and thus torque, but if you increase the voltage to compensate the torque will go up. A controller with speed feedback will do this automatically. Obviously the available mechanical power goes down if you reduce the speed at the same torque, this is the laws of physics.

Robert G8RPI.

This is an old thread, but it contains a worrying comment from john swift 1

"they provide a practical solution in the form of a switch to disconnect the earth connection from the EMC filter"

You should NEVER, EVER REMOVE THE EARTH from an mains EMC filter for any reason. Doing so will leave the body of the filter (and possibly the entire equipment) "live" and an electric shock hazard.

The manual John linked to describes removing or disconnecting the filter completely (not a good idea as the drive will cause interference and is therefore illegal). However in that manufactures smaller drives this is done by pulling a tab that disconnects the filter.

As suggested by Gary an isolating transformer should prevent the tripping, but it brings it's own issues. The drives are industrial components and should really be installed in a circuit with correctly sized protection. Unfortunately most domestic "part P" electricians (and at least 1 supposed industrial one I've met) don't understand the requirements.

Robert G8RPI