Making work equipment.

[JellyParticipant @jelly]

[JellyParticipant @jelly]

Have any of you in the past made bits of equipment for your employer; and if so have you had any issues or experiences to share from doing so?

I recently built an air powered Vacuum ejector (“Venturi Pump”) for a specific task, after a discussion with one of my managers about having been working on (steam) injectors the previous weekend on seeing it worked they deemed fit to repay my costs via expenses.

Subsequently, the H&S Dept first asked if it was CE marked (by a curious co-incidence, a Venturi falls outside the 6 possible EU directives you might expect it to be covered by, and therefore is not eligible for CE marking), and subsequently conclude that this ‘home made’ equipment cannot be used, as the firm would have the product liability for it in the event of an accident.

I left it at that, as as H&S are ultimately doing their jobs correctly to protect the company and its employees. However it has been raised that the business routinely manufactures and adapts equipment in house (as any firm with a decent team of fitters would), and this is no different, so I may yet be asked to go back and make a case for this bit of kit.

I have all the drawings, calculations and details to affirm that it was suitably designed and manufactured (I originally foresaw having to CE mark it, so needed to compile a technical file to issue the declaration of conformity), so it shouldn’t be a huge issue to confirm it as being at least as safe as any commercial off the shelf model, but In all honesty I’d perfectly happy to chalk this up to experience and maintain cordial terms with the H&S team.

[Michael GilliganParticipant @michaelgilligan61133]

A lot depends on the working environment in which the equipment is being used.

… If it legitimately qualifies as an experimental lab [or any suitable alternative description], things are much easier than if it's a production line.

MichaelG.

[Nathan SharpeParticipant @nathansharpe19746]

To the best of my knowledge Godwin pumps used (and probably still do if Godwins still exist) a venturi air extraction/vaccum pump on their engine driven centrifugal pumps to evacuate air within suction pipework. This was driven by a standard Bendix 2cyl compressor into a jet at 90 deg from a similar jet on the suction hose side , the air was ejected via a shaped nozzle at 90 deg from the suction nozzle. These were not CE marked as an individual component/system (circa 2003 ) but CE compliance may have been due to the whole pumpset being CE compliant. If I remember correctly all items were standard Bendix part no's. We had a leachate Eductor system as part of the hire fleet (SLD pumps) which used the same system. Nathan.

[Nick_GParticipant @nick_g]

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What is going to be the future of the CE mark in a couple of years when we have finished bailing from the EU.??

I remember when if something was marked 'Made in England' it was a sign of sufficient quality to satisfy most.

Nick

[JellyParticipant @jelly]

Nathan,
That’s interesting stuff, AFAIK Godwin now trade as a brand of Xylem Water Solutions, who bought them to add pumps to their offering.

I’m aware of a number of firms offering similar C.o.t.s. vacuum systems, but mostly at a small scale for laboratory purposes, if Bendix produce versions which can evacuate piping systems at a sensible rate (I’m instinctively imagining 3″ or 4″ nominal size), that could be of interest as a replacement.

Nick,
I suspect we’ll keep seeing it as both British products will be sold to the EU and European ones to Britain.

We did invent and popularise the idea of a conformity marking in the form of the BSI Kitemark after all, so it would be unsurprising if we continue using our own good idea.

[vintagengineerParticipant @vintagengineer]

The CE mark is worthless as the Chinese have adopted the CE to be used on their export goods. CE = Chinese Export!

[SillyOldDufferModerator @sillyoldduffer]

I'd suggest this isn't your monkey Joshua.

On the surface the problem is very simple: does the item you made that was exploited by the company need a CE mark or not? If it does, then you produce the Technical File etc. as you described.

Unfortunately, your H&S department may have lifted the lid on a much more serious issue. As a business it appears that your employer does not understand the rules behind CE marking. (Or at least they've not been able to explain them to you!) The implication is that the business may not be meeting it's legal responsibilities on a larger scale, and that they will be liable if something goes wrong.

I think this is one for your manager. Ask him 'What's the company Policy on CE Marking' If there isn't one, suggest politely that's a management problem.

You may be unlucky and be given the job of writing the Policy. Not impossible, you wrap a wet towel round your head, take advice, and work out the answer. Even better, pay a consultant to write it.

Once the policy has been signed off by the boss, whenever H&S ask about CE Marks, you tell them that you follow Company Policy. And a Policy is a jolly good thing to have in the event the Company gets sued: it proves the business is not negligent and/or incompetent.

Putting this tactfully could be a good test of your people skills!

Dave

[Ian PParticipant @ianp]

If this bit of equipment (a one-off from your description) is something the company use in house it does not need to be CE marked. You did not manufacture and market it to them, and they paid you as part of your salary.

Ian P

[Phil WhitleyParticipant @philwhitley94135]

As said above, the CE mark became virtually worthless more than a couple of years ago, and it only ever meant that it was approved to be marketed within the EEC, which everyone assumed meant that it met some ethearal, unspecified safety standard. If you are able to show that your design meets accepted engineering margins of safety, then you should be good to go. the problem is not in the design, it is in the H&S departments blind acceptance of CE to mean it is safe, it is essentially an arse covering excercise which states that if it explodes and kills somebody, it is not their responsibility, and good luck with getting any compensation from whoever (if anybody actually does) police the CE mark!!

[MWParticipant @mw27036]

Posted by Phil Whitley on 30/03/2017 21:41:57:

As said above, the CE mark became virtually worthless more than a couple of years ago,

I'd agree with this, most of them are simply printouts and stickers from china, it's basically fraud if they haven't actually had it inspected under that criteria. (Although we lack the means to directly enforce it, hence why they get away with it.)

I've worked for a number of businesses and they treat a BSI mark like gold dust, so I take it theres still worth in that because it must be tested by their inspectors. The BSI qualifications are treated as much harder to achieve even under fair conditions, and just because you get it one year, doesn't mean you'll get it again.

Michael W

Edited By Michael-w on 30/03/2017 21:49:04

[JellyParticipant @jelly]

Dave,
Thankfully there is a series of policies in place regards the requirement for CE marking of equipment, and a separate policy which is linked to the Management of Change policy for determining if new CE marking is required when equipment or repaired or adapted.

We may also have a policy specifically for equipment which logically seems that it should be CE marked, but actually is not in scope, and thus legally cannot be, and the compiling and holding of a Technical File and conformity assessments to satisfy PUWER98 requirements, something I believe has been done at least once before.

I suspect the major issue is that it’s an unusual situation, in an area of both dense and consequential legislation. I’d be inclined to start by saying no and move to asking questions later too if I was in the shoes of our H&S team.

[Anonymous]

Do I take it that the equipment in question is for use in the factory only by the company concerned? If so then it does not need to be CE marked. The key phrase for CE marking is "placed on the market", ie, it is being sold on the open market. In that case the product needs to be CE marked, if it falls under items which should have a CE mark. However, if the product is for internal use, and is not on the open market then it does not need CE marking. That's not to say that a safety assessment is not prudent, but that's nothing to do with CE marking.

Andrew

[SillyOldDufferModerator @sillyoldduffer]

That puts a different complexion on it Joshua. There are certainly grey areas, for example the rules being different if the thing is electrical or a machine and if it is 'placed on the market' or 'brought into service'.

From a business perspective they have to balance the cost advantage of your excellent solution against the cost disadvantage if something goes wrong. Those who dismiss 'arse covering' would no doubt reconsider if it were their botty in line for a good reaming!

I agree with you: there are two sides to the argument. In a way you're in a good position – you get the glory of having made something that worked, while avoiding the brickbats if it ever went wrong!

Dave

Edited By SillyOldDuffer on 30/03/2017 22:28:01

[MuzzerParticipant @muzzer]

CE marking is not "virtually worthless". It's what stops you getting killed or maimed. And if you find something claiming to be CE marked that clearly shouldn't be, you should report it. It's a criminal offence to sell stuff that does not meet the safety regs, whichever ones apply to that piece of equipment.

When we "take back control", the regulations will be exactly as before, except they will be BS versions rather than EN BS. There isn't going to be any relaxation of standards, as they represent many decades of lessons learnt, lives lost and empirical testing, as well as gradual "harmonisation" across the globe.

It's clearly very easy to be all juvenile and cynical about this but almost regardless of where you go in the world there are strict regulations on safety standards. And anything that needs to be capable of sale in the EU will need to be CE marked. No problem – the UK regs will be identical anyway.

Murray

[Michael GilliganParticipant @michaelgilligan61133]

Well-said, Murray

The only thing I would add is that the 'Chinese Export' mark differs subtly [*] from the European 'CE Mark' … Which is, presumably, how they get away with it.

MichaelG.

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[*] it's in the kerning

Compare a typical 'Chinese Export' mark with the CE mark shown here: **LINK**

http://www.underhillengineering.co.uk/CE-Marking

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Easy comparison here: http://www.icomuk.co.uk/News_Article/3794/17103/

 

Edited By Michael Gilligan on 31/03/2017 08:34:43

[John FlackParticipant @johnflack59079]

Michael W……..was the BSI really that good. I remember , perhaps in the 60s they came up with tolerances for the old type hand drills(the ones with the bevels and handle). The mfrs protested and the tolerances were reduced by 400 percent. Which begs the question as to who runs the BSI and who benefits? Like a lot of legislation if it's "About right" for "Some " it's "near enough"

[Brian HParticipant @brianh50089]

Please do not open the **LINK** in the post from Michael Gilligan. My Malwarebytes reports it as a virus.

Brian

[Michael GilliganParticipant @michaelgilligan61133]

Posted by Brian Hutchings on 31/03/2017 08:57:04:

Please do not open the **LINK** in the post from Michael Gilligan. My Malwarebytes reports it as a virus.

Brian

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Interesting observation, Brian

The URL seems innocent enough from here

… and was disclosed, for the benefit of the wary, immediately below the **LINK**

MichaelG.

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I have no knowledge of "Malwarebytes" so can't comment on its credibility.

.

EDIT: I have just checked, using 'Succuri'

This also reports a problem with the underhillengineering site:

https://sitecheck.sucuri.net/results/www.underhillengineering.co.uk/ce-marking

If we have any experts in this field, perhaps they could advise.

Apologies for any inconvenience caused by my innocent attempt to help. 

 

 

Edited By Michael Gilligan on 31/03/2017 09:31:29

[Russell EberhardtParticipant @russelleberhardt48058]

Posted by Andrew Johnston on 30/03/2017 22:14:40:

Do I take it that the equipment in question is for use in the factory only by the company concerned? If so then it does not need to be CE marked. The key phrase for CE marking is "placed on the market", ie, it is being sold on the open market. In that case the product needs to be CE marked, if it falls under items which should have a CE mark. However, if the product is for internal use, and is not on the open market then it does not need CE marking. That's not to say that a safety assessment is not prudent, but that's nothing to do with CE marking.

Andrew

Refreshing to see a reply from someone who knows rather than from "knowledge" gained from reading the likes of the Daily Mail scare stories.

Russell

[Michael GilliganParticipant @michaelgilligan61133]

For my penance … here is the definititive European 'CE Mark'

Copied from that troublesome 'underhillengineering' page:

.

MichaelG.

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P.S. The culprit appears to be 

https://cdn.cookiescript.info/

but I'm not making that an active link.

Edited By Michael Gilligan on 31/03/2017 09:54:29

[John FlackParticipant @johnflack59079]

May I at, at a risk of pedancy, ask if this forum is the correct place to raise matters legal and production in relation to commercial activity? Giving advice in such circumstances may have legal implications. I have believed, perhaps in innocence, that model eng…….etc titles-indicated a hobby undertaken by amateurs.

Where exactly are "we" going with such matters.

[SillyOldDufferModerator @sillyoldduffer]

Posted by Michael Gilligan on 31/03/2017 09:44:21:

…

P.S. The culprit appears to be

https://cdn.cookiescript.info/

but I'm not making that an active link.

Edited By Michael Gilligan on 31/03/2017 09:54:29

Yep, that's the bad boy. The underhillengineering site appears to be kosher BUT their CE page has been compromised. The CE page contains an embedded link to a blacklisted site associated with phishing and other scams. The bad link link is activated simply by reading the CE Page.

Don't Open the CE Page. (Unless you enjoy taking risks!) Although we don't know what the payload does, we do know that the site hosting it is blacklisted. It's a known troublemaker, not to be trifled with. It's possible, but not guaranteed, that your ISP will block it for you. It's possible, but not guaranteed, that your computers security software will block it for you. As Clint would say: "Do you feel lucky, punk?"

Now we know it's malware, the safest countermeasure is simply to avoid it.

Dave

[CirclipParticipant @circlip]

Does the machine in the O/P work safely providing the operator is using it correctly? ( Yes, I know you should USUALLY design so an untrained monkey can't hurt itself).

Overnight "Get the show back on the road fixes" (M16 x 25mm LH capscrews?) and various other small and time saving exercises were never paid for but were always regarded as "Yea, but that clever s*d has got us up and running AGAIN, cos he's an ingineer".

As it's an "Internal" machine and not being marketed, just make sure that when the "Elfins" stalk round, it's stuck under a bench as "EX" equipment.

Pillar and bench drill chuck guards were always quickly refitted be fore they descended on the workshop.

Regards Ian.

[SillyOldDufferModerator @sillyoldduffer]

Posted by John Flack on 31/03/2017 10:42:12:

May I at, at a risk of pedancy, ask if this forum is the correct place to raise matters legal and production in relation to commercial activity? Giving advice in such circumstances may have legal implications. I have believed, perhaps in innocence, that model eng…….etc titles-indicated a hobby undertaken by amateurs.

Where exactly are "we" going with such matters.

I would say 'yes' because the Forum caters for wide ranging interests. It's not just about Models, or even about working metal. There's plenty of overlap with other technical hobbies and with professional experimental and industrial work.

Some people make parts for motorbikes. It's important for them to understand what you can and cannot do to the brakes, especially if you do the work for someone else, profit from it, or have a crash due to faulty workmanship. Although I'm unlikely to work on bikes myself, I find their discussions interesting and sometimes valuable. Ditto aircraft, astronomy, electrical and many other examples.

I think anyone reading the threads should do so in the full knowledge that Forum members aren't always experts and are certainly not expert in everything. I hope we all understand that pleading 'not guilty' on the basis of something read on this forum would cut no ice whatever in court.

Opinions about exactly what our hobby is vary and they're 'not-wrong'. I met a chap at an Exhibition who was emphatic that 'Model Engineering' means nothing but making accurate miniature steam locomotives. I respect his position and was very impressed with his work, but it's not what I want to do in my workshop.

Cheers,

Dave

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