保管好你的作业相关文件资料

Taking care of the paperwork

LEEA经常会接到产品用户和供应商有关于高架起重吊装设备应附带哪些资料文件的问题。仅以英国的情况而言，虽然大部分的相关行业法规早在20世纪90年代便开始实施，但围绕一些具体问题仍然还有很多人都存在着理解不清的状况，为作业安全事故的发生埋下了一定的隐患。

At LEEA we regularly receive calls from both end users and suppliers with questions regarding the documentation that should accompany overhead lifting equipment. Even though, in the UK at least, most of the relevant legislation has been in place since the 1990s, there is clearly still widespread confusion and misunderstanding surrounding this particular issue. This can present a number of potential dangers for those concerned, including the consequences of failing to meet basic legal requirements. Furthermore, whilst it’s quite possible that equipment without the right paperwork is perfectly sound and fit for purpose, mistakes and omissions in the documentation provided by the supplier should at least raise some doubts in a buyer’s mind.

人们最容易理解错误的是，认为一份测试证明在新设备供应时是照例应被要求提供的。实际上，这种理解在现在的行业发展趋势下早已不适应了。过去，我们对新的吊装设备进行例行的过载测试，目的仅是为了证明其负载能力可以达到规定水平。但是，我们现在的行业发展状态更加强调整个产品制造过程中的质量控制，并且以抽样检验、无损检测和其他一些技术手段来取代单一目的的试验负荷测试（通常是没有实际意义的）。因此，测试证明这类文件也被制造商证明取代了。现在，对于吊装设备的购买方和供应方，应当关注三类重要文件：制造商证明、产品合格证和全面检验报告。

 By far the most common misconception is the belief that a ‘test certificate’ is routinely needed when new lifting equipment is supplied. Indeed, the documentation that accompanies new lifting equipment is regularly and erroneously referred to as such. In fact, test certificates generally belong to a bygone era in which every new item of lifting equipment was routinely proof load tested with an overload to prove it could carry the rated SWL (Safe Working Load). Things have moved on and far greater emphasis is now placed on quality control during the manufacturing process. Sampling, non-destructive testing and other techniques have replaced a single (and often meaningless) proof load test. As a result, the ‘test certificate’ has been superseded by the ‘Manufacturer’s Certificate’. Along with the EC Declaration of Conformity and Report of Thorough Examination, it is one of the three key types of document that buyers and suppliers of lifting equipment should concern themselves with.

制造商证明上应显示的信息，也应该出现在相关的产品标准上，这是一项强制性规定。所以，制造商如果宣称符合某项产品标准，就必须出具制造商证明。

    The information that should be contained in the Manufacturer’s Certificate is listed in, and a compulsory part of, the relevant product standard. Therefore a manufacturer claiming to comply with the product standard must issue the Manufacturer’s Certificate.

制造商必须按照法律规定提供规定的文件。在欧洲，是指一份EC产品合格证，相关要求在欧盟机械指令中有完整的说明。依照欧盟机械指令的要求，EC合格证必须由负有相应法律责任的人来签署出具。如果产品是在欧洲经济区内制造的，应由制造商来签署出具，否则应由制造商的授权代表或进口商来负责。相关立法对于此合格证的内容有明确和具体的要求说明。需注意的是，EC合格证和制造商证明通常都有些重复性的内容信息，所以制造商是可以选择将这两份文件合并作为同一份文件出具的。

 The manufacturer must also supply the document required by legislation. In Europe, this means an EC Declaration of Conformity. The requirements for this are contained in the Machinery Directive, the latest version of which came into force in 2009 and is implemented via national legislation in countries throughout Europe. In the UK, this is represented by The Supply of Machinery (Safety) Regulations 2008. According to the Machinery Directive, the EC Declaration of Conformity must be produced by the ‘responsible person’. If the item is made in the EEA (European Economic Area), then the responsible person is the manufacturer. However, if it is manufactured outside the EEA, the responsible person is the manufacturer’s authorized representative, or the importer. There are clear and detailed requirements for the content of the Declaration of Conformity, which can all be found in the relevant legislation. The Declaration of Conformity must accompany the item in question, and it should be noted that there will usually be some overlap of the information contained in this and the Manufacturer’s Certificate. Indeed, the manufacturer may choose to combine the two documents. This is perfectly acceptable, provided the information is clear.

以上提到的重要文件中的最后一份是全面检验报告。英国的法律要求按照吊装作业与吊装设备管理规范（LOLER）中第9条的要求来进行全面检验。所谓的全面检验，是指一种高级别的定期性吊装设备检验工作，包括有任何形式的测试项目，只要这是设备检验工作所需要做的，如功能测试、电气测试、无损检测和负荷测试等。此规范所带来的主要变化之一是，每次全面检验工作完成后，都要出具一份报告，不论被检设备是否可以继续安全使用。

The last of the three key documents is the Report of Thorough Examination. The UK requirement for Thorough Examination is found in Regulation 9 of the Lifting Operations and Lifting Equipment Regulations (LOLER). Under LOLER, the term thorough examination is used to describe high level, periodic inspection of lifting equipment. It includes any tests deemed necessary as part of the examination, such as functional, electrical, non-destructive and load tests. One of the major changes introduced by LOLER was that a report must be issued following every thorough examination, regardless of whether the equipment is found to be safe or not. Schedule 1 of LOLER clearly specifies the information that a Report of Thorough Examination must contain, but it should be noted that LEEA regularly comes across examples of incomplete reports.

除以上三种重要文件类型以外，我们有时可能还会在合约上要求供应商提供其他一些形式的认证文件，比如测试负荷证明和无损检测证明。但是，应该强调的是，这些文件类型都不是吊装设备适用管理法规所要求必须提供的。

Beyond these three key documents, there may sometimes be contractual requirements on the supplier to issue additional certification. Examples include a Certificate of Test Load Applied, Certificate of Non Destructive Testing, or an EN10204 Certificate of Conformance (sometimes referred to as a mill certificate). However, it should be stressed that these have no direct legal status in relation to lifting equipment, although they may be needed to support the legal requirements for such equipment, for example in the compilation of a technical file.

有时候，繁多的产品文件资料对于保证吊装作业的安全和高校进行会起到一定的反作用，好在提供这些文件资料的法律责任落在了供应商一方。可以肯定的是，对于非专业的购买设备的一方，想准确判断购买设备的质量好坏几乎是不可能的，而EC合格证则为证明设备是否符合机械指令要求提供了最直接的物证。而且，是否能够理解并符合这些系统性规范性文件要求，也可以体现设备供应商在产品供应环节的专业性和可靠性。

Documentation and paperwork can sometimes be considered a distraction from the important business of ensuring safe and efficient overhead lifting. The good news is that the obligations are not unduly onerous. Indeed, they can provide a useful tool for buyers. Certainly, for the non-specialist buyer, it is often all but impossible to make a considered judgment on the quality of equipment being purchased. The EC Declaration of Conformity provides the main, if not only, physical evidence that the equipment complies with the requirements of the Machinery Directive. Furthermore, a supplier that clearly understands and adheres to the requirements for accompanying documentation should go at least some way towards assuring the buyer of their credibility and professionalism.