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Komo Machine Inc., Sauk Rapids, MN, manufactures computer-numerical-control (CNC) machining centers, custom-- made and standard routers, and automated machinery for the refrigeration industry. A few years ago, it decided to sell its milling machines in Europe. That seemed simple enough, until the company learned that its machines would have to bear the DTI CE marking.
"If you want to sell your product in Europe," stated quality engineer at Komo, "you have to comply with certain directives and there's not really much you can do about it." Komo was primarily concerned with the possible costs and time involved in undergoing certification. But, after learning that it would not only have to undergo CE marking, but also obtain the help of a notified body if it wanted to sell overseas, it resigned itself to the challenge. Garmon was placed in charge of the CE-- marking venture.
His first step was self-education. The company is a member of the Association for Manufacturing Technology (AMT), McLean, VA, an organization of machine-tool manufacturers. AMT provided Garmon with a list of member companies that had undergone CE marking, whom Garmon contacted and interviewed. He also visited the U.S. Dept. of Commerce Web site for information. During this time of intense research, Garmon felt particularly swamped with the sheer volume of information available on the CE marking.
"You get tons and tons of literature," Garmon explained, "and you start reading through it, and you start going a little bit crazy." He began to realize that the company would require some outside assistance.
After some investigation, Garmon found QNET LLC, a CE-marking consultancy based in Elk River, MN. He chose QNET because it had ties with ERA Technology Ltd., a testing house in Leatherhead, Surrey, England. ERA performs testing and consulting for the CE marking and similar standards. It promptly sent a representative to evaluate Komo's operations and products for risk assessment.
ERA used a "cookbook-style approach" with Komo. Thirty days after its representative performed the risk assessment, ERA sent Komo the "first chapter," which essentially was the first chapter-the risk assessment-of the technical file. In the risk assessment, the representative noted where the company would have to make changes to its machines to comply with the directives, and offered recommendations on how to do it. Garmon copied the information and put it in a spreadsheet, which he called the "task list." For each safety improvement that had to be made, Garmon assigned an appropriate person within the company. For instance, if an electrical assembly had to be redesigned, the task would be assigned to the company's electrical engineer. If the engineer felt he could comply with the directive in a way other than that suggested by the ERA representative, he was free to do so.
Komo had to make no major changes to its machines, other than adding some interlocks and other safety features, and changing a controller around. One area that did cause concern was electromagnetic compatibility (EMC) testing. The machines were subject to the EMC directive because they used electricity, and had to be tested for their immunity to emissions and for their own propensity to emit. Komo was warned of the possibility that circuits in the machine could be fried during testing, but fortunately, this did not happen, and the company successfully completed this phase of DTI CE marking certification.
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