# A question to all you Europeans out there.



## vederstein (Nov 22, 2014)

Warning:  This is a pseudo questions/rant.

As some of you I design machines for the manufacturing and medical industries.  Recently the company I work for has been getting international and shipping some machines to the EU.

Here's my question:  With all the documentation, tests, safety requirements that conflict (or don't make sense at all), how do you actually manage to get anything made?

I thought OSHA was bad, but the EU is nuts.

An example:

All machine components must be grounded to another.  In America, we just ground through the bolts.  In the EU, all components must have its own ground strap (base to plate to frame to door etc).  Each strap must be tested that it actually grounds.

Here's where I think it's gone a bit nutso:  Anodized aluminum must have the the anodize removed prior to installation of the grounding strap.  But the grounding stud is threaded into the plate and was tapped after the anodizing.  So even though the ground stud is touching non-anodized aluminum and the ground strap is touching the stud, this according to the Germans that are reviewing this machine isn't good enough!??!!  :wall:

Another example:

It's common that all safety devices (if they are not interlocked) to require tools to remove the device (e.g. a cover panel must require a screwdriver or wrench to remove if it's not interlocked with the safety circuit).  My customer wants the fasteners securing the safety interlock devices drilled out so they can _never_ be removed - even with tools.  This makes them unserviceable.

That's just one example.  These regulations are causing me migraines!!!!

On one of the large industrial steam engines in Britian, there's a plaque on the machine:

"This machine has no brains.  Use your own."

I wonder if the EU has any brains?

...end rant.

...Ved.


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## xpylonracer (Nov 23, 2014)

Hi Vederstein
If your company wants to sell machines in Europe that can kill if not used properly they have to comply with EU Legislation. The point you make about the interlocked switch being removed is just one such safety feature on many machines, usually the guards being removed where injury to personnel may occur is well documented.
The point regarding removal of anodizing from an earthing point is also valid in providing a low resistance path for any fault current, in your example only one side of the lug will be in contact with earth via the nut to stud threads. I'm surprised the company buying the machines didn't request barrier grease at any point where dissimilar metals meet.
Many years ago I worked in the motor manufacturing industry, even in those days any cars being exported to the USA had special adaptions to comply with US laws, so what your'e complaining about is not a new thing, just the other way round.
Employers in Europe have a duty of care for the safety of their employees so this means implementing such machinery safety requirements as deemed necessary.
I'm surprised to know that in the land of litigators there are no such requirements.
Emgee


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## kadora (Nov 23, 2014)

After reading your article i think that your legislation is nonchalant
 to people  health.


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## Nick Hulme (Dec 14, 2015)

Brussels constantly passes ridiculous laws that benefit no-one but the big businesses providing back-handers to the bent unelected officials, the elected ones go along with it all to stay on the gravy train :fan:

 - Nick


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## goldstar31 (Dec 15, 2015)

I would agree with most of the foregoing but would respectfully comment that a lot of us  Brits know more about football than we do about what goes on in Europe.
France- despite all that we have read about in Paris, isn't France. Nor, for that matter is Spain  where the average Brit is content to get pie-eyed or topless or whatever one does on an artificial tower block apartment that overlooks imported sand onto a sea soaked in Factor whatsit sun oil.

It isn't like that, most of the regions are wanting home rule rather like the Scots from the English yoke. Spain is wanting to break up into old divisions like Catalonia from Madrid.

And suppose that it is ll fine and dandy with the common currency, the Euro. Not so- one can cross borders and buy things with Euro cash but try to use a French cheque in Euros but in Germany which uses Euros  or whatever,  It simply doesn't work without heavy surcharges.

I'm sorting out- or more correctly trying to sort out my wife's and my estates. So far, I have two houses within 250 miles of each other and two different sets of laws- one for England and one for Scotland which is-dammit- less than 50 miles North of here. I'm sitting on the Roman Wall or more correctly bits of it are my boundary to one house.

As for Spain - no one knows whether I get all my house or half my house or three quarters.

For automobiles , we drive on two sides of the road, we have vehicle tests every one year or every two years or when we sell the vehicle.  If you drive in Germany on an autobahn the speed limit is - well anything except when it isn't whilst it is 80 on a French motorway- if it is not raining but if you are driving into Austria from Germany you must put your running lights on but if it is raining in most places in Europe, you put your lights on anyway. In England, you don't need to.

That's only a bit of it- confused. If you aren't you haven't been following my discourse.

Norman


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## Nick Hulme (Dec 15, 2015)

If something is sold to you based on either a lie or with a game changing bit of information withheld then the transaction is clearly fraudulent. 
I give to you "Ever Closer Union", and also ask what kind of "Close Union" hangs out a member to dry when that union prevents them from devaluing their currency locally and improving trade, tourism and thus national income in the conventional way?


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## james_III (Dec 15, 2015)

vederstein said:


> "This machine has no brains.  Use your own."
> 
> I wonder if the EU has any brains?



Nope, brains were donated before EU was born, just to make sure nothing makes any sense at all. There is problems when importing machinery etc to EU, but if machinery is build inside EU not so much trouble. Actually machine can be lethal and still  sold everywhere and nobody cares. 

Example wood chipper without proper guards and emergency stop, nobody cares until first really fatal injury, then insurance officials come and investigate what happened and manufacturer agreed to fix those problems with new machines. Of course most important thing found in every machine is CE sticker, so don't forget to print one if you are selling machinery. CE should stand something for safety etc etc but it is nothing more than joke. Manufacturers can alter designs after they get CE certificates and that's completely legal....

My too close to arctic circle perspective  *club*


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## jimjam66 (Dec 15, 2015)

Crazy seems to be a global thing.  If you've ever tried to take an orange (the fruit) into California, you'll know.  Or a haggis into - well, anywhere in the US.

And then there's the drone problem.  Oh wait - it's not a problem anymore, they have to be registered by law.  There now, that wasn't so hard ... or was that just because there wasn't a super-rich National Drone Association lobbying congress?


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## kf2qd (Dec 15, 2015)

I think the problem that he is describing is that there is a different set of rules for each country, and some of the rules conflict, meanning that you need to produce several versions of the machine to comply. 

For machinery coming to the states there is one set of rules (and maybe California) that apply so you only need to export 1 machine.

I see it as a way for the Europeans to protect their manufacturers from competition with U.S. manufacturers. One set of rules for EU members, and another set of rules for outsiders...


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## xpylonracer (Dec 15, 2015)

kf2qd

The reason for stringent machine specifications in the EU is a mixture of safety precautions from each member state, before the EU was formed each country had their own ideas about safety in the workplace, surely it is good practise to incorporate all of the safety features into machine and plant where workers safety is concerned.

As said in my earlier reply if the EU manufacturers want to export machinery and/or plant to the USA or any other country outside of the EU they have to meet the safety requirements of that country. 
It is not unreasonable or protectionist for EU countries to expect imported machinery and plant to comply with EU regulations.

What is protectionist is the amount of import duty and VAT added to imports from non EU countries, but I guess that's the same in most countries for the home workshop.
Businesses are not so effected by the addition of VAT as if registered they claim it back.

Emgee


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## jimjam66 (Dec 15, 2015)

kf2qd said:


> I see it as a way for the Europeans to protect their manufacturers from competition with U.S. manufacturers. One set of rules for EU members, and another set of rules for outsiders...



Swap out 'European' and "EU' for 'American' and 'US' and you have described the US auto industry.


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## hanermo3 (Dec 16, 2015)

The OP is misinformed, and flat out wrong.

I sold about a 100 industrial cnc machines, made by a major Us mfct, and none of them had any of the features mentioned.
I also looked at about 2000 machines, in 200 workshops, I visited, while my sales team visited about 1500 workshops, in the country of Spain.

Based on working in industrial machine tool sales, and looking at machines in finland, spain, sweden, belgium, and some in usa and mexico, fwiw.

The EU regs are simple.
The implementation is varied, and there is a huge amount of FUD.

Wherever the original info came from - they are probably sincere, but misinformed.

Looking at current imported machines from Mori Seiki, DMG etc. separate ground straps dont seem to be required, nor for other import brands.
The 20 spanish manufacturers still here (was 54 manufacturers about 20 years ago, I have a list, and know all their turnovers, personnel, billing/person, profitability etc.)  dont make such, etc.
Fasteners are normal, and removed with normal tools.

Enclosures are requred for cnc tools, and there is debate on auto doors, and auto parts changers. 
Regs are unclear.
Implementation varies.

"Safety relays" are required, but any 2 relays crosss wired constitute a safety relay.
Tends of thousands of non-prctected cnc routers are sold every year, non-enclosed, from all manner of brands.

IE most of the stuff You hear is FUD.
I have actually read the regs, its not hard, and they are not long.

Basically, machines must be as safe as possible, and the importer (or eu manufacturer) declares it, and its then EU approved. Sticker on. Legal.
There is no testing, and no approvals as such.

Its at the peril of manufacturer to define what is safe, and the EU sticker you put on means that you keep a "file" of the specs YOU wrote up.

Most of the process is simply FUD to employ lawyers and consultants.
Neither really helps, as anyone can still sue you, in reality. 
It just reduces risks of success.

Major pay-outs are unusual or unknown. 
There are no class actions as in the USA. Same -same, but different.


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## rad1945 (Dec 16, 2015)

Hi People, 
Please remember there are three parts to what we all nonchalantly  call the EU.
The EU is the part concerned with international trade and more specifically with trade between EU member countries.
Then there is the Shengan Abkommen which allows free movement by citizens between the member countries.
Last, the European Central Bank. financing Greece, etc.  Britain is a member of the EU but not the other two.
After the lesson, the main point that potential exporters wishing to sell to EU member countries is that the rules have to fit all countries in and outside the EU.
The fine print with electrical is that you shall comply with IS 3000 which is a world wide standard.  With all due respect, and based on my 25 years working for a major American contractor and supplier, US companies don't, only with a gun and their heads.  The electrical work in some countries both within and outside the EU is somewhere between horrendous and bloody horrible.  Grab the standard first, Read the book and then you will know what you need and how to allow for it in your quote. Or say too hard and find another victim to sell to.  
Russell A DUNN  PE
Ferlach, Austria.


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