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Risk assessment machine - Delivery of documents to foreign customers Community

Question:

I have provided to our customer (based in Poland) the documentation for the machine that we have delivered them for several months. The documentation included the Operation and Maintenance Manual, User Manual for the panel (in practice the user manual for additional display with which it controls the whole machine), electric and pneumatic diagrams, the machine program and other manuals in pdf format for additional accessories mounted on the machine. Everything in both paper and electronic.

Now these customers have asked us recently to send additional documentation translated into Polish (not other languages, otherwise not included), which consists of the documents "Risk Analysis" and "Risk Assessment".

The question is, given that there are also middle-of-payments ... : We, as a company, especially on the basis of the existing Directive 2006/42/EC, we have to send them these documents??

And if not, they can, under the existing provisions of legislation that I just mentioned, block parties (even small) payment due to the lack of one or both of these documents?

As a point of Directive 2006/42/EC (which I have written and electronic copy in pdf format) can show precisely to emphasize to these guys that they have no right to ask what documentation?

How are things under the law?

Answer:

Allego la guida alla direttiva macchine, dove può trovare sicuramente risposte più esaurienti (in inglese).

L’art. 5 della direttiva 2006/42/CE elenca gli obblighi del fabbricante prima dell’immissione sul mercato.

Si intuisce chiaramente che i punti c (istruzioni), e (dichiarazione CE), f (marcatura CE) sono da fornire al cliente, mentre i rimanenti punti rimangono procedure interne.

Meglio specificato ancora nell’art. 12 che rimanda all’Allegato VIII, e quindi allegato VII parte A (se read them all these references, she'll understand if you are following the certification process correct for your type of product).

The last reference (Annex VII Part A of course) is the most significant response to your questions (below with my comments):

Part A of this Annex describes the procedure for 'compiling a technical file. The technical file

must prove that the machine complies with the requirements of this Directive. It must, as far

where this is necessary for this assessment, design, the manufacture and operation of the machine. The

technical file must be compiled in one or several official languages \u200b\u200bof the instructions for the machine

are exceptions to this rule, for in fact they should be applied to the special provisions

by 'Annex I, Section 1.7.4.1.

Unlike the instructions, the technical file must NOT be written in the language of the client, but in any language EU (eg the manufacturer)

1 . The file technical and include the following elements:

...

the documentation on risk assessment demonstrating the procedure followed

...

So the risk assessment is part of the dossier Technical

2. The technical dossier referred to in paragraph 1 shall be made available to the competent authorities of Member States

for at least 10 years from the date of manufacture of the last unit produced in the case of manufacturing

in series.

technical file does not have to be located within the Community, nor be materially

always available. The However, it must be assembled and made available in a timeframe

with its importance by the person named in the declaration of conformity.

The technical file need not include detailed plans or any other specific information

for sub-assemblies used by the manufacturer of the machinery unless a knowledge of them is essential for

verification of compliance with the essential safety and health protection.

3. Failure to submit the technical file in response to a duly substantiated request of the authorities

national authorities may constitute sufficient grounds for doubting the conformity of the machine in question

essential requirements of safety and health protection.

This last part escape any doubt: The technical file (and thus the risk assessment, or that part) can be obtained only by a judicial authority stability Community .

It can be concluded therefore that your client can claim nothing on this document.

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Ex Libris (8)

From "The ardor " by Roberto Calasso:
What
dhi? Intense thought, vision, inspiration, meditation, prayer, contemplation? Time to time, all of this. And in any case, the assumption was the same: the primacy of knowledge than any other way of salvation.


There is no doubt that the Vedas, the Vedic knowledge of men, a knowledge appeared in northern India about three thousand years, as illustrated by Calasso, is both far and near.

certainly belongs to us the primacy of knowledge, certainly not belong to us (except for small groups of mystical / s) steps visionary and contemplative.

But it is, strutturatasi even in its present form over the years, something with out having to cope with. ?
I think so: India, with its billion people (not to mention, for now, China, or Indonesia, or Nigeria, or Brazil, or South Africa, etc..), Is now a global benchmarks.

And then, sooner or later, we find that if we (as needed) to continue to manage and deliver on a global level, cargo (including hazardous), we must deal with a culture (and therefore with the customs, practices, regulations ) different from ours.

Maybe I did not think so when (and I really think!) That began end of Western civilization. However
prepare to deal with other civilizations is now necessary. And, if I was right, history teaches that when you are faced with difficult challenges (the decline of a civilization), can (must) be "born" new ideas, new projects, new possibilities (such as says an old saying : help wit the difficulties ).

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Registration TRECCANI.it portal for comment on the interesting article by Norberto Bobbio on natural law and legal positivism.

Why is this recording? In order to post a comment to the interesting article, limited to 1000 characters the following:

Title: REPORTING new protagonist natural law ...

IDEA ... with unpublished, based on actually lived, and still live in "perfect happiness" in terms of "fullness of being."

I registered just to comment on and honor the memory of Norberto Bobbio.

What is the 'alert'?

This is an appeal at the last minute of 13/06/1994, submitted to the Minister of Justice, Alfredo Biondi lawyer Mr Berlusconi of 1, enclosing a copy of my original composition MINUTE delivered personally, on 04 / 05/1994, all'emerito Dear Professors Raffaele Ajello, I asked about natural law. They spent more than 16 years, has still not received a response.

I know well, like Linotype typesetter, the successor of Professor Ajello, Professor Aurelio Cernigliaro clear.

That action is published. PDF at:

http://inenascio.splinder.com/media/22982786

assure you of my total availability (24/24 hours ) who is seriously interested in learning more.

Sincerely

Inenascio Padidio

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Ex Libris (7)

The second chapter of the novel " Snow" by Orhan Pamuk begins:

The snow always gave a feeling of purity that made him forget the dirt, mud and darkness of the city. But Ka lost this feeling the first day he spent in Kars. Here the snow was exhausting, annoying and exhausting.


So two aspects of the snow a bit 'as it happened to me.
On the one hand, a few weeks ago, the whitewashed garden, silent, recalling the opening words of the above mentioned book:
The silence of snow, thought the man sitting behind the driver of the bus. If this was the beginning of a poem he called "the silence of snow" that he felt inside.

other hand, the reference to a reality made uncomfortable by reading some articles of law, such as Article 28 of Legislative Decree 205/2010, introducing, in the Decree 152/2006, the following new Article 214-bis:
1. Snow removal activities carried out by governments or their representatives, dealers network infrastructure or infrastructure is not keeping for
letter a) paragraph 1 of Article 183.

A when another article that will define how not waste the rain water flowing on the streets?

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UNI EN ISO 12100: Safety of machinery - General principles for design - Risk assessment and risk reduction

Hi

It seems to me useful information that was released in November 2010 under the new UNI EN ISO 12100: " Safety of machinery - General principles for design - Risk assessment and risk reduction " .

This standard overcomes and absorbs the 14121-1 12100-1 and 12100-2 is the latest to 2009.

R iPort below the original text where English is defined as acting accordingly:

" This document Supersedes EN ISO 12100-1:2003, EN ISO 12100-2:2003, EN ISO 14121-1:2007.

This second edition cancels and replaces ISO 12100-1:2003, ISO 12100-1:2003 / Amd. 1: 2009, ISO 12100-2:2003, ISO 12100-2:2003 / Amd. 1: 2009 and ISO 14121-1:2007 Which of it constitutes a consolidation without technical changes. Documentation (Eg risk assessment, type-C standards) based on Replaced These documents need not be updated or revised. "

therefore do not need to update the documents produced by the UNI above, but it is preferable quoted in D Declaration of Global C ONFORMITY the latest version.

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err "humanum est" ... but not for the ECHA!

The weekly online Hazardous Cargo Bulletin, "in its latest issue (January 20, 2011), takes the news of ECHA (European Agency for the chemicals ) relating to notifications received classification and labeling, noting that, after saying that he had received 3.1 million notifications of 24,529 substances, the same ECHA has subsequently corrected the last digit in 107,067.

Certainly this is not a "small" correction. But
is undoubtedly a bit 'strong conclusion of the weekly online
"T he size of the error will doubtlessly Provide Further ammunition for Those Who Feel That ECHA is an incompetent and Unnecessary Bureaucracy . "

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Ex Libris (6)

Leafing through the book" Gödel, Escher, Bach: an Eternal Golden Braid " Douglas R. Hofstadter (sooner or later, perhaps, be able to read, if the neurons and will help me) I could not see, from inveterate and unrepentant smoker, the quotation from a poem by Bach, entitled "Thoughts of a smoker edifying tobacco, "which begins:



Often at sunset
my pipe of good tobacco fill, and here for my beloved
sit and smoke
and calms the mind in this gloomy picture is the
of life.



I think it would be nice if all s many s we could every now and then to "stop" to reflect calmly (even without a cigarette or cigar or pipe!).
It may happen that, lazing and freeing the thoughts, come up with an idea of \u200b\u200bhow to make it less dark hours later, dominated by get headaches from the regulations on the management and transport of dangerous goods.

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Ex Libris (5)

The book I have in my hands is " The museum of paper and printing of Siva," a book that reminds me of a failure.


The museum in question was (now do not even know if there is still and in what conditions) in the seat of Siva in the Via Salaria in Rome.

And I could see in the days (years ago) where I was trying to convince the then ANPA (ora ISPRA) ad acquisire (praticamente gratis !) l’intero complesso per farne la propria sede. Anche perché erano presenti e funzionanti alcuni laboratori, fra i quali quello dedicato alle prove sugli imballaggi (anche per merci pericolose).

E il fallimento ( nel senso che non se ne fece nulla; gli edifici, e i laboratori, sono stati a lungo abbandonati; e adesso sono utilizzati, forse, non ne sono sicuro, per alloggio temporaneo per senzatetto ed immigrati ) mi si è ripresentato adesso che, come sapete, ci sarebbe necessità di laboratori specializzati per le prove sui prototipi di imballaggi per merci pericolose (e mi riferisco in particolare alle nuove prove di vibrazione richieste per i GIR/IBC for transport of liquids)

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DEDICATED TO ...

... how many / which i think is enough to attend a course of several hours to become expert / s ADR or CLP and REACH ... ... how many
/ i think they can express opinions and give advice without spending days and days to read and understand the ADR or CLP and REACH ...





From Dialogue (Mon Yu) of Confucius: Chapter II

Verse 15


Confucius said
Studying without thinking is useless
Thinking without studying is dangerous

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Past or future?

While in Italy continue to circulate old industrial polluting vehicles, the Port of Seattle prohibits ( see this page) entrance for vehicles manufactured before 1994.

While in Italy are closed on a growing number of rail freight terminals in Canada, USA and Mexico (see this page ) growing the rail freight.

But perhaps it is logical enough, since Italy is increasingly a country of old (and would even more if it were not for immigrants).



The three ages of man Giorgione

alternative? Perhaps, if the / young people finally wake up (and have been shown to do so: see the recent demonstrations by students, researchers, casual), and if the elders, instead of defending their privileges, giving them a hand.

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Ex Libris (4)

epilogue of his book "The Science universal art and nature in the genius of Leonardo " Fritjof Capra says:

Evolution is no longer considered a competitive struggle for existence, but rather a collaborative dance whose driving forces are the constant emergence of new creativity.



would be nice if it were so: but these days seems to prevail instead of the competitive struggle.
But perhaps if you look in the perspective not restricted to the quota, there is still room for creativity and innovations.

relate however to those who are oppressed by the competition (and who is on their side) to "create", "innovation", "change" to bring out the dance instead of fight.

In small, it can mean, for example, engage in an active role in the provision of innovative legislation, including in the field of management and the transport of dangerous goods, but not limited to struggle to avoid being overwhelmed s by law "unjust."

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YEAR 2010 to 20 th anniversary of my "happy solitude" out of the Family.

Two events have disturbed my birthday alone at the end of 2010 and, I think, the party of every Italian citizen with the so-called "goodwill" :

1) failure to extradited to Italy from Brazil, made by the outgoing President Lula da Silva, of the Italian citizen Cesare Battisti, Revolutionary Armed to the Communist Party (CAP), sentenced to four life terms in Italy, having been convicted of multiple murders;

2) the loss of life of the young 24 year old corporal, Alpine Mat MIOTTO, the victim of a sniper in the "peace mission" in Afghanistan.

The only solace in these two unpleasant news was the successful end of year speech to all Italians, the President of the Republic, Mr Giorgio Napolitano.
This video announces the end my next video response to our dear Mr. President.

In my purpose, issue of videos aimed at achieving genuine common good, the end of our blessed Constitution.