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Post by ayesha2 on Jul 15, 2009 15:47:06 GMT
Hi russel
filled the boiler from a marked 2 litre vessel
had exactly one litre left , had some spill out so i would say just under 1 litre
yours tony
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russell
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Post by russell on Jul 16, 2009 11:39:54 GMT
Then, according to the rules as I understand them it should (must) not me CE marked.
Russell.
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Post by mutley on Jul 16, 2009 13:07:46 GMT
Hi All Have a look at this document. www.conformance.co.uk/directives/ce_pressure.phpThis talks about a pressure greater than 0.5bar as interpreted in the UK. The full EU directive can be found here... eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31997L0023:EN:HTMLthis states that.. whereas for pressure equipment defined in this Directive which presents only a minor pressure hazard and for which certification procedures are therefore not justified, the CE marking will not be affixed. and defines minor pressrue hazard as equipment subject to a pressure of not more than 0,5 bar does not pose a significant hazard due to pressure; whereas there should not therefore be any obstacle to its free movement within the Community; whereas this Directive applies to equipment subject to a maximum allowable pressure PS exceeding 0,5 bar. No mention of capacity... If think most of our boilers work above 0.5bar pressure. Ultimately the boiler maker has to work to the guidleines as interpreted by his notified body. Cant remember of the top of my head at the moment but do the SF rules make any mention of capacity or just bar liters? I seem to remember that they require any professionally made boiler to comply with the above directive and be CE marked as appropriate. To try and answer the original question. The CE mark indicates that the boiler makers work has been assesed and meets an appropriate standard that his notified body is happy with. The insurance company requires it for proffesionally made items so it has a value. Just my thoughts. Andy
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Tony K
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Post by Tony K on Jul 17, 2009 8:47:10 GMT
To try and answer the original question. The CE mark indicates that the boiler maker's work has been assesed and meets an appropriate standard that his notified body is happy with. The insurance company requires it for professionally made items so it has a value. On the face of it this looks OK - but I would have liked to see something laid down as to how often that assessment needs to be renewed. I think a responsible manufacturer might spend a day, once a year with his notifiable body (due to cost), reviewing the technical file for each item and his records with evidence of what he has constructed and his design criteria in each case, with a few items available for inspection. Anyone purchasing a professionally built boiler might wish to discuss this conformance with the provider - a responsible one will no doubt be delighted, an irresponsible one less so! Thank you everyone for contributing. I think the night is a little brighter for me and certainly not how I thought it was.
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kwil
Part of the e-furniture
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Post by kwil on Jul 17, 2009 8:48:45 GMT
Andy,
The parameters of the Link to CELEX are incorrect for some reason
K
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Post by havoc on Jul 17, 2009 10:52:47 GMT
That's not the way the system works. And it doesn't have to because (in case of boilers) each get checked, so you could consider that an ongoing inspection. The notified body also doesn't need to check his technical files because likely 90% of what is in it are their reports anyway and those files are "static", they never change once the item certified. I even think that you may not change it. It is in fact more a kind of safeguard against manufacturing faults and cowboy practitioners: it checks that it has been build correctly, with the correct materials and procedures (if applicable) and is tested for the first time. Once the boiler has been certified, it is the regular (club) inspections that take over and keep a trail of inspections and tests.
So if a boilermaker makes more than a single boiler a year he's going to spend more than a day a year at the notified body discussing his work, believe me.
Don't think those notified bodies take these things lightly! Becoming a notified body is serious work and expenses. Every test tool and everyboby manipulating them has to be rigourously verified, calibrated, tested, examined etc. The people working there don't seem to do more than routinely test but they have to be knowledgable of every aspect of the standards they work with (and get examined about them). One of the labs we work with has just changed hands, it got a new owner. All the rest stayed the same: location, equipment, people working there etc. Just because the owner changed and everybody got new cards and briefpaper next year the complete certification will have to be done from the ground up. Not just the ongoing checks, the full monty. Just like they never did this before and bought all new with people that just came out of school.
We do electronics at the office and before a product is ready for final testing you easily spend a week or more preparing, preliminary tests, making changes etc. Right now we are re-designing some boards because a failed EMC test. It took 1 week testing and documenting and trying to get it through the tests. Now we have 2 weeks redesign, 2 weeks for production and then again 1 week preliminary testing followed by final test (2 days). Spending a day discussing which tests have to be done or how a particular test has to be done is normal. Total cost about 20000 euro.
Don't think a boilermaker is just going to pickle his last piece and dump it at a notified body...
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russell
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Post by russell on Jul 17, 2009 11:00:56 GMT
The copy of the Directive linked to by Andy has some typos. A better copy can be read direct from the EC here: ec.europa.eu/enterprise/pressure_equipment/ped/directive/index_en.htmlAll pages are headed "This text is for information only, it has no formal status." because only the copy published in the Official Journal has formal status. However it is accurate. Article 3, 1.1 explains that the 0.5 bar limit some have referred to only applies if the P.V product is greater than 25 bar.litres. That is to say, it only applies to large vessels. Article 3, 1.2 gives the 2 litre limit that Havoc and myself have referred to. I know that the Directive is difficult to follow but, if you look at the flow chart in Guidelines 2/13 it clearly directs you to table 5 of Annex II for steam engine boilers. This shows that boilers of less than 2 litres are covered by Article 3 para 3. Article 3, 3 includes the following: "Such equipment and/or assemblies must not bear the CE marking referred to in Article 15." Thus, boilers of less than 2 litres must not be CE marked. Regards, Russell.
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Post by mutley on Jul 17, 2009 11:14:58 GMT
The interpretation is the issue here. The health and saftey website has a document that states the directive is not legally binding. Section 2 in the followimg document. www.hse.gov.uk/foi/internalops/fod/oc/300-399/308_14.pdfwhat the EC directive says , according to my interpretation, is that vessels above 2L must have a CE. I cant see anywhwere that says you cant CE mark one below 2L. And that is the issue here, how diffrent bodies interpret those regs. regards Andy
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Tony K
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Post by Tony K on Jul 17, 2009 12:25:06 GMT
I think a responsible manufacturer might spend a day, once a year with his notifiable body (due to cost), reviewing the technical file for each item and his records with evidence of what he has constructed and his design criteria in each case, with a few items available for inspection. I am trying to discover how the system REALLY works. I thought I knew, but Havoc has shattered my illusion. The difference between our boilers and electronic items, it seems to me, is that we have one-offs. Havoc suggests all boilers will have been inspected and approved individually before CE marking. I cannot believe boiler manufacturers are doing this - somewhere I have seen the cost is £450 - £500 per day plus expenses - so say £700 per day, which, on a monthly basis would mean £8k5 p.a. If they make £500 profit per boiler, they would have to make 17 Pansy sized boilers before they break even on that, let alone other costs. Given the above, boiler makers will be doing the minimum necessary to comply. I cannot see anywhere that it is compulsory to inspect each one and therefore I bet they are not doing it and my previous suggestion is near correct. Not wishing to offend, but where the size limit is has little interest to me - since most of our boilers are above all the limits quoted so far. I am very much open to criticism, rotten tomato throwing, being burned at the stake, tarring & feathering, keel hauling, being put on the rack - whatever. Feel free to do that. ;D
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russell
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Post by russell on Jul 17, 2009 12:47:37 GMT
Andy, The document you site doesn't state that the Directive is not legally binding. What it does state is that the guidlines to the directive published on the site I referred to are not legally binding. However it does go on to say that they are "the official interpretation of the Directive across the EU and should be treated accordingly". Regarding marking of boilers of less than 2 litres look at table 5 of Annex II and then Article 3 para 3 of the Directive.
Tony, You are quite right. Boilers of less than 50 Bar.litres do not need to be inspected by a notified body.
Regards, Russell.
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Post by havoc on Jul 17, 2009 13:52:59 GMT
Well, they are one-off's in the sense of having to pass the hydraulic test each of them. As I understand it, they put boilers together in a lot and test more than one of them in a single day. If you put 3 boilers in a lot and test them in a day at £600/day then it is £200/boiler. If I see what a boiler costs then I think this is covered. Why do you think boilers are so expensive? They pass such costs to the clients, they don't pay those costs with their profit!
That £500/day is cheap, we pay about 1000-1500 euro/day for EMC testing at a notified body.
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S.D.L.
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Post by S.D.L. on Jul 17, 2009 21:30:44 GMT
what the EC directive says , according to my interpretation, is that vessels above 2L must have a CE. I cant see anywhere that says you cant CE mark one below 2L. And that is the issue here, how different bodies interpret those regs. Andy Looking at www.berr.gov.uk/files/file11284.pdfStarting at pdf page 9 Determine classification, ie steam generator (boiler) is on chart 5. See pdf page 25:- Below 2 liters constructed according to sound engineering Practice PSV Pressure*Volume less than 50 (1 litre at 50 bar or 2 litres at 25 bar etc) Cat 1 vassal PSV >50 but less than 200 then Cat II vassal etc To see requirements of Cat I or II etc go to pdf page 14 so Cat 1 needs module A, Cat II Requires Module A!, D1 and E1 etc See pdf page 5 for requirement not to fit CE mark if covered by SEP " bear specified markings (but not the CE marking)." Steve Larner
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Tony K
Elder Statesman
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Post by Tony K on Jul 19, 2009 8:21:51 GMT
Why do you think boilers are so expensive? They pass such costs to the clients, they don't pay those costs with their profit! OK, I did say I was willing to be treated like an idiot, but they are in business to make money, charging what the market will stand and they make more profit if they do the inspections once per year rather than paying for inspecting each item. Again, I cannot see anywhere that it is compulsory to have each one inspected - and if I was a manufacturer I would not do it. So, I will stick my neck out and say I think CE marking has minimal value and just adds to the cost. Rather than relying on CE marking I suggest a better approach to buying a boiler.... - Visit the manufacturer before placing an order
- Discuss boilermaking and view some of the work - 5 mins will tell you what sort of person he/she is and your eyes will tell you the rest.
- If impressed - define what you want, discuss it, place order and wait.
- Attend to see your boiler at the last point you will be able to see inside (possibly just before the back is put on) - a responsible manufacturer will have no problem with this.
- Attend to witness the hydraulic test.
- Treat the CE mark as a low value, expensive legal necessity run by too many nerds and those sucking off it.
- Check the paperwork, pay up, and enjoy your boiler.
Simples!
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Post by ayesha2 on Jul 19, 2009 9:13:05 GMT
without prejudice
Hi tonytrans
to your last post HEAR, HEAR
bit rough on them like me with no transport ___BUT I AGREE.___
the CE mark is just used to con people, you must have one or you can,t use it
it is used to hide behind when the goods are not up to the standards set down for the CE mark.
taking 2 steps back and looking at all the info supplied by all the participating members in this post, i for one appreciate their effort to try and clarify the meaning, the reason, and requirements for it
IN MY OPINION at the end of the day it is only a set of standards for manufactures to follow in making there products, when and if they follow them
has it appears the monitoring and quality control of products is left to their discretion?.
where has in a club, the boiler is monitored at least twice by the inspector and a witness before brazing and during testing, hydraulic and steam
yours tony
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kwil
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Post by kwil on Jul 19, 2009 13:25:19 GMT
Have we all got there at last?
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Tony K
Elder Statesman
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Post by Tony K on Jul 19, 2009 15:14:20 GMT
Mmm! I think I have. Thanks to all. Finished with main engine - or as they say in "The Dambusters," Radiator shutters to automatic!
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Post by ayesha2 on Jul 19, 2009 17:36:29 GMT
Hi all
WOTS NEXT
a list of the good un,s
or a list of the bad un,s
or shall we start another thread on say what constitutes a good joint in a jointed barrel from a flat sheet, and how it should be done but of course not the professionals way, no thank you.
of course this is without prejudice
yours tony
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Post by mutley on Jul 19, 2009 18:33:45 GMT
Hi Tony,
Sounds like you are going to start making a boiler! A brave plan for any but the experienced among us! - unless you are experienced of course (apologies if you are) - do you have some new design techniques to share with us? We would all of course be most interested to hear any guidance you may have to offer. Look forward to hearing from you :-).
regards
Andy
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Post by ayesha2 on Jul 19, 2009 22:50:52 GMT
HI andy
whoes bin talking
i have built 2 minnie boilers, scrapped both, 1 had fire tube damaged but i used silphos i think, then i saw article in model engineer on the effect of the coal gas, second one i heated a second time forget what for and the throat plate parted because i did not heat the boiler all round only concentrated on the one area, rebrazed with a strengthening piece, but did not like it too risky for my liking, wedding tackle in the fire line so to speak and scrapped, still have so your welcome to look at em. and i think i have a part finish rainhill boiler some where
are you referring to my jigs what ever, for making belpaire boiler front plates, they were only seen yesterday, if so news dunt half travel fast
yours tony
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