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  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
  • Carlos M. Bello Rodriguez v. Plakos Scrap Processing, Inc.Torts - Product Liability (Defective Machine) document preview
						
                                

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FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 Exhibit “B” FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 GENECO DTX 4/600 HYDRAULIC SHEAR OPERATOR’S INSTRUCTION AND SERVICE MANUAL CUSTOMER MACHINE SERIAL NO. KW/HP/AMPS MOTOR RATING HYDRAULIC PRESSURE WHEN ORDERING SPARE PARTS, ALWAYS QUOTE ITEM NUMBER, DRAWING NUMBER AND MACHINE SERIAL NUMBER OR STOCK NUMBER Gensco Equipment (1990) Inc. e-mail: info©genscoequip.com 53 Carlaw Avenue, Toronto, Ontario Canada M4M 2R6 URL: www.genscoequip.com Telephone: 416-465-7521 In the USA 800-268-6797 Fax: 416-465-4489 Serving indusrtial markets world-wide since 1919 FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 GEN5CO WARRANTY ALL ORDERS FOR PRODUCT ARE SUBjECT TO THE FOLLOWING: Gensco Equipment (1990) Inc. warrants each product to be free from defects in material and workmanship under normal use and service. Gensco Equipment’s obligation under this warranty is limited to repairing or supplying, at our option, a part or parts to replace any defective part or parts which fail, within one (1) year from date of original sale. No product shall be returned without prior authorized approval, and if authorized, the transportation charges shall be prepaid to Gensco Equipment, Toronto, Canada, or Gensco America, Decatur, GA. Unauthorized returns will not be accepted. The provisions of this warranty shall not apply to any part or parts which have been subject to misuse, negligence or accident, or which have been repaired or altered outside of Gensco Equipment’s service department in any way, so, as in the judgment of Gensco Equipment to affect adversely its performance, stability or reliability. Gensco Equipment neither assumes nor authorizes anyone to assume for it any other obligation or liability for any loss or damage, either direct, incidental or consequential, resulting from or arising out of, or iii.connection with, any of its defective part or parts. THIS WARRANTY IS EXPRESSLY IN LIEU OF ANY AND ALL OTHER WARRANTIES, EXPRESSED OR IMPLIED, INCLUDING ANY IMPLIED WARRANTY OF MERCHANT ABILITY OR FITNESS FOR A PARTICULAR PURPOSE, AND OF ANY OTHER OBLIGATION OR LIABILITY ON THE PART OF GENSCO EQUIPMENT OF ANY NATURE WHATSOEVER. RETURN POLICY A Returned Goods Authorization must be obtained from Gensco Equipment prior to the return of any product. All shipments to us must be sent freight prepaid. Upon inspection, should the Quality Control Department determine the product to be defective, credit will be issued accordingly. For product returned in an “as new” condition, the restocking charges are as follows: RETURNED FROM DATE STOCK ITEMS SPECIAL ORDER ITEMS OF ORIGINAL SHIPMENT 120 Days 20% 50% FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 DO NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 NOT OPERATE WITHOUT GUARDS IN PLACE FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 I N IS RA P IN CE IFTHIS ACHI EDO S 0TH AG AR INSTALL D ONOT RATE WEAR SAFETY GLOVES AND EYE PROTECTION AT ALL TIMES. UNDER NO CIRCUMSTANCES IS THIS MACHINE TO BE OPERATED WITHOUT THE GUARD PROPERLY INSTALLED AND SET TO THE LOWEST POSSIBLE POSITION. DO NOT REACH INTO THE MACHINE AT ANY TIME WITH THE MACHINE ON.. DO NOT ATFEMP TO TOUCH THE BLADES OR TO CLEAN THE BLADES OR ANY PART OF THE SHEARING AREA WITH THE MACHINE ON. DO NOT CLEAN THE MACHINE OR PERFORM ANY MAINTENANCE WITH THE MACHINE ON. DO NOT CLEAN UP ANY SCRAP AROUND THE MACHINE WITH THE MACHINE ON. DO NOT FORCE MATERIAL INTO THE MACHINE. DO NOT A1TEMPT TO SHEAR: ENCLOSED CONTAINERS, CYLINDERS, JARS, GAS AND PROPANE CYLINDERS. ANYTHING THAT MAY CONTAIN EXPLOSIVE, VOLATILE OR ACID MATERIAL DO NOT A1TEMPT TO SHEAR HARDENED STEEL PINS OR ANY MATERIAL YOU ARE UNSURE OF. STOP , TURN OFF MACHINE AND ASK FOR MORE INFORMATION. KEEP THE MACHINE AND THE ENTIRE WORK AREA CLEAN. KNOW WHO IS WORKING AROUND YOU AND MAKE SURE NO ONE ELSE COULD COME CLOSE TO THE SHEAR AREA OR COULD BE HURT BY FLYING DEBRIS. RK R T STI 0110 P AS ,U I IN F IS ILEI SI E IN. SO TLOKUTN A R TS. F U EROU FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 SAFETY PRECAUTIONS RECEIVED NYSCEF: 02/03/2021 IMPORTANT WARNING These safety precautions Read related safety pre have been prepared to assist the operator and maintenance personnel cautions before operating in practicing good shop safety procedures. this machine. Failure to Operator and maintenance personnel must read and understand these follow safety instructions precautions completely before operating, setting up, running, or per may result in serious per forming maintenance on the machine. sonal injury. These precautions are to be used as a guide to supplement safety pre cautions and warnings in the following: a. All other manuals pertaining to the machine. WARNING b. Local, plant, and shop safety rules and codes. In orderto clearly show de c. Federal and national safety laws and regulations. tails of this machine, some covers, shields, guards, See the latest edition of the OCCUPATIONAL SAFETY AND barriers, devices, or doors HEALTh STANDARDS, available from the DEPARTMENT OF LA have either been removed BOR, WASHINGTON, D.C. or shown in an “open” position. All such protec GENERAL SAt-t~T~’ INSTRUCTIONS AND CONSIDERATIONS tive components must be installed in position before PERSONAL SAFETY operating this machine. Failure to follow this Machine owners, cporators~ setup men, maintenance, and service per instruction may result in sonnel must be aware of the fact that constant day—to-day safety pro serious personal injury. cedures are a vital part of their job. Accident prevention must be one of the principal objectives of thejob regardless of what activity is involved. Know and respect your machinery. Read and practice the prescribed WARNING safety and checking procedures. Make sure that everyone who works for, with, or near you fully understands and — more importantly — com Failure to follow instruc plies with the following safety precautions and procedures when operat tions on this page may re ing this machine. suit in serious personal in jury. Sudden movements, loud noises, horseplay, etc., must be avoided. These distractions may result in unsafe conditions for those working near the machinery. Observe and follow safety instructions such as BNO SMOKING~, ~High Voftagetm, ~DANGER~, etc., in your working area. Accidents can occur that result in serious personal injury to yourself or others due to clothing and other articles becoming entangled in cutters, hand wheels, levers, or moving machine elements. The following suggestions, if followed, will help you to avoid such accidents: Neckties, scarfs, gloves, loose hanging clothing, and jewelry such as watches, rings, or necklaces must not be worn around moving machinery. Re strain long hair with a cap or net. Wear gloves only when handling rough, sharp, or hot parts. Use safety protective equipment. Wear clean approved eye or face protection. Safety—toe shoes with slip-proof soles can help you avoid injury. Keep your protective equipment in good condition. Never operate or service this equipment if affected by alcohol, drugs or other substances or conditions which decrease alertness or judgment. Page 1 FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 WORK AREA SAFETY RECEIVED NYSCEF: 02/03/2021 WARNING Always keep your work area dean. Dirty work areas with such haza~ Failure to follow instruc- as oil, debris, or water on the floor may cause someone to fall to the floor, tions on this page may se- into the machine, or onto other objects resulting in serious personal iriju suit in serious personal in- I)’. Jury. Make sure your work area is free of hazardous obstructions and be aware of protruding machine members. Return tools and similar equipment to their proper storage place im mediately after use. Keep work benches neat, orderly, and clean. Report unsafe working conditions to your supervisor or safety depart ment Items such as: worn or broken flooring, ladders, and handrajls, unstable or slippery platforms, or scaffolds must be reported and re paired before use. Do not use skids, work pieces, stock, machines, tote pans, and boxes as makeshift climbing aides. TOOL SAFETY Sharp edged cutting tools must be handled with gloves or a shop cloth. Inspect cutting tools before use and reject defective tools. Remove hand tooling such as wrenches, measuring equipment, ham mers, and other miscellaneous parts from the machine immediately af ter usage. LIFTING AND CARRYING SAFtTY Contact supervision if you have any questions or are not sure about the proper procedures for lifting and carrying. Before lifting or carrying an object, determine the weight and size by re feriing to such things as tags, shipping data, labels, marked informa tion, or manuals. Use power hoists or other mochaniäal lifting and carrying equipment for heavy, bulky, or hard to handle objects. Use hookup methods recom-. mended by your safety department and know the signals for safely di recting a crane operator. Never place any part of your body under a suspended load or move a suspended load over any part of another person’s body. Before lifting, .be certain that you have a safe spot for depositing the load. Never work on a component while it is hanging from a crane or other lifting mecha nism. Always inspect slings, chains, hoists, and other lifting devices prior to use. Do not use lifting devices found to be defective or questionable. Never exceed the safety rated capacity of cranes, hoists, slings, eye- bolts, and other lifting equipment Follow standards and instructions ap plicable to any lifting equipment you use. (For example, ANS1 Standard B18.15, available from The American National Standards Institute, Inc., 1430 Broadway, New York, New York 10018, contains information con cerning safe liftingloads for different size eyebolts, for various angles of lift and application instructions for safe use of eyebolts.) Page 2 FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 Before inserting an eyebolt, be certainRECEIVED NYSCEF: that both the eyebolt 02/03/2021 and the hol~ WARNING have the same size and type threads. To attain safe working loads, a least 90% of the threaded portion of a standard forged eyebolt must b~ Failure to follow instruc engaged. tions on this page may re sult in serious personal in INSTALLATION AND RELOCATION SAFETY jury. Before lifting the machine, consult the machine manual for proper methods and procedures. An electrician must read and understand the electrical schematics prior to connecting the machine to the power source. After connecting the machine, test all aspects of the electrical system for proper functioning. Always make sure the machine is grounded properly. Place all selector switches in their OFF or neutral (disengaged) position. The doors of the main electrical cabinet must be closed and the main disconnect switch must be in the OFF position after the power source connection is corn. plete. Always lock the main disconnect device in the OFF position if the ma chine is left unattended, unless machine is part of an unmanned manufacturing system and in a production cycle. When the machine is installed, be sure that the motors rotate in the proper indicated direction. SETUP AND OPERATION SAFETY Read and understand all the safety instructions before setting up, oper ating, or servicing this machine. Assign only qualified personnel, instructed in safety and all machine functions, to operate or service this machine. Operators and maintenance personnel must carefully read, under stand, and fully comply with all machine mounted warning and instruc tion plates. Do not paint over, after, or deface these plates or remove them from the machine. Replace all plates which become illegible.~ Safety guards, shields, barriers, covers, and protective devices must be connected or in place before operating the machine. All safety features, disengagements, arid interlocks must be in place and functioning correctly prior to operation of this equipment. Never by pass or wire around any safety device. Never brake or slow down moving machinery with your hand or with some makeshift device. Never use machine power to remove a nut from any shaft. The spindle and slides must be stopped when measuring work pieces, changing tools, or removing chips and grit. Remove chips and grit with a chip rake or brush, not with your hands. Page 3 FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 Keep all parts of your body off the machine table, table edge, out of th path of moving units, trip dogs, trip plungers, and out of the working area WARNING during operation. Never lean on a machine or reach over or through Failure to follow instruc machine - you can become entangled in tooling and other movin tions on this page may re elements or you may accidentally activate start buttons, feed controI~ suit in serious personal in rapid traverse controls, power work holding control, or similar devices. jury. During operation, be attentive to the machining process. Excessive vibration, unusual sounds, etc., can indicate problems requiring your immediate attention. Watch for conditions such as packed chips or grit which can cause breakage of tooling or machine elements. Shut off power to the machine when leaving the operating area or at the end of your work period. Never leave the machine running unattended, unless machine is part of an unattended manufacturing system and in a production óycle. Turn the master disconnect device to the OFF posi tion before cleaning the machine at the end of the working day or when guards or covers are removed that expose hazardous areas. MAINTENANCE SAFETY Do not attempt to perform maintenance on this machine until you read DANGER: and understand all the safety instructions. HIGH VOLTAGE Assign only qualified service or maintenance personnel to perform Before working on any maintenance and repair work on this machine. Consult the service electrical circuits, turn the manual before attempting any service or repair work and when in doubt machine Main Disconnect contact the Factory. Use only original replacement parts: others may Device “OFF” and lock It. impair the safety of the machine. Before performing maintenance or service work, Warning or Danger signs must be placed conspicuously about the machine. Before detaching counterweights or driving UNDER NO mechanisms, vertical sliding members must be blocked properly. See the CIRCUMSTANCES IS ANY Service Manual for proper dismantling procedures. MAINTENANCE, Before removing or opening any electrical enclosure, cover, plate, or CLEANING, REPAIRS, door, be sure that the Main Disconnect SWitCh is in the OFF position. If ALTERATIONS, any tool is required to remove a guard, cover, bracket, or any basic part ASSEMBLY OR of this machine, place the Main Disconnect Switch in the OFF position, DISASSEMBLY OF THIS lock itin the OFF position. If possible, post a sign at the disconnect MACHINE OR ANY OF ITS switch indicating that maintenance is being performed. PARTS ARE TO BE ATTEMPTED WHILE THE Whenever maintenance is to be performed in an area away from the dis • MACHINE IS IN connect and the disconnect is not locked, tag all start button stations OPERATION OR IF POWER with a ~DO NOT START tag. Adequate precautionS~ such as locks on IS CONNECTED. circuit breakers, warning notices, or other equally effective means must be taken to prevent electrical equipment from being electricallY acti vated when maintenance work is being performed. Before attempting to adjust, repair, or perform maintenance on electri cal circuits connected with yellow wires, first find the source of power, turn it off,and lock it in the OFF position. Machine tool interlock control circuits connected with yellow wires are powered from a source away FAILURE TO FOLLOW from the machine and carry voltage even when the machine’s main dis THIS INSTRUCTION MAY connect devise is turned to the OFF position. RESULT IN DEATh OR SE RIOUS PERSONAL When removing electrical equipment, place number or labeled tags on SHOCK INJURY. those wires not marked. If wiring, is replaced, be sure it is of the same type, length, size, and has the same load carrying capacity. Close and securely fasten allguards, shields, covers, plates, or dàors before power is reconnected. Page 4 FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 I WARNING Failure to follow tions on this page instruc may re An electrical technician must analyze the electrical system to determine, the power possible use retaining of power retaining devices must safe before maintenance is performed. be devices such disconnected, as capacitors. discharged, or Such made sult in serious personal in Working space around electrical equipment must be clear of obstruc~ jury. tions. Provide adequate illumination to allow for proper operation and maintenance. MATERIALS USED WITH THIS PRODUCT Various materials may be used with this product. Before using/mixing! diluting materials with this product; contact the manufacturer/autj~ rized supplier of the material to determine that the material is suitable for the intended application and request a Material Safety Data Sheet (MSDS) from the material manufacturer. Pages. FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 DELTAX RESERVES THE RIGHT TO ALTER THE PRODUCT SPECIFICATION OR TECHNICAL INFORMATION IN ANY WAY WITHOUT GIVING PRIOR NOTIFICATION. ALL RIGHTS AND TECHNICAL MATTER RELATING TO THE PRODUCT REMAIN THE PROPERTY OF DELTAX AND MAY NOT BE COPIED, REPRODUCED, MANUFACTURED OR USED FOR DESIGN DERIVATIVES NOR ANY INFORMATION TRANSFERRED IN WHOLE OR IN PART TO ANY UNAUTHORISED PARTY WIThOUT THE EXPRESSLY WRITTEN CONSENT OF THE ABOVE NAMED COMPANY. THE WARRANTY OF THIS MACHINE CAN BE INVALIDATED BY OPERATIONAL ABUSE AND IN CERTAIN CIRCUMSTANCES THE OPERATOR MAY BE LIABLE UNDER SECTIONS OF THE HEALTH AND SAFETY AT WORK ACT 1974. IT IS STRONGLY URGED THAT THE CUSTOMER STUDIES THE ACT BEFORE OPERATING THE MACHINERY. IT IS RECOMMENDED THAT PROTECTIVE CLOTHING IS WORN WHILST OPERATING THE MACHINE~Y. # WARNING II DO NOT ATTEMPT TO TOUCH OR CLEAN THE BLAI)ES WITH THE MACHINE ON. DO NOT ATTEMPT TO FORCE MATERIAL INTO THE MACHINE. DO NOT ATTEMPT TO SHEAR: ENCLOSED VESSELS, CYLINDER, GAS BOTTLES, ETC. EXPLOSIVE, VOLATILE OR ACID MATERIAL AND HARDENED STEEL PINS OR OTHER HARDENED PARTS. ALWAYS ISOLATE THE MACHINE BY SWITCHING OFF AND REMOVING THE PLUG BEFORE ANY SERVICE WORK IS CARRIED OUT, OR WHEN NOT IN USE. ALWAYS KEEP THE MACHINE IN A CLEAN, DRY AND TIDY ENVIROMENT. ALWAYS WORK SAFELY WITH DUE RESPECT TO YOURSELF AND OTHERS. Pt FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 1. Tank unit. 11. Hydraulic oil level sight glass. 2. Shear body. 12. Electrical control box. 3. Shear head. 13. Covers. 4. HydrauLic cylinder. 14. 5. Blades. 15. Foot control pedal. 6. Blade securing bolts. 16. Control cable. 7. Blade adjusting screws. 17 Incoming mains lead. 8. Stroke Limiting cyLinder. 9. Stroke adjustment knob. 10. Hydraulic oil, filler cap. P FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 HOW TO SET-UP AND OPERATE YOUR MACHINE a) Upon delivery it willbe necessary to connect the electrics and foot control cable. These willbe found coiled inside the machine, and can be accessed by the removal of the side cover mounted around the electrical box (see Fig. 1; items 12 & 13) b) The machine must be positioned on level hard standing. c) A wall isolator is required with a socket and a plug. 3 phase: 15 amp supply. d) Link the foot pedal and control cable together (see Fig. 1; items 15 & 16) as drawn below, taking great care not to overbend or deform the control cable. FIG.2 1. FOOT PEDAL 4. PROTECTION CAP 2. CONTROL CABLE 5. CLEVIS 3. ADJUSTER AND LOCKNUTS 6. CLEVIS RETAINING PIN & CLIP 7. LOCKNUT Assemble the items as shown so that when the foot pedal is fully depressed, a gap of approximately 2mm. exists. This position being adjustable by item 3 in Fig. 2. Do not overtighten these tocknuts. FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 e) A competent electrician is required for any electrical installation or service. Ensures rotation is correct (i.e.with the rear cover removed the motors shall run in the same direction as the white arrow or when viewed from the rear in a clockwise direction. Single phase machines can be directly plugged into a socket as a plug is supplied. f) The equipment runs on a hydraulic pressure system which isset on leaving the factory and should not be tampered with. OPERATION THE WARRANTY OF THIS MACHINE CAN BE INVALIDATED BY OPERATIONAL ABUSE AND IN CERTAIN CIRCUMSTANCES THE OPERATOR MAY BE LIABLE UNDER SECTIONS OF THE HEALTH AND SAFETY ACT OF 1974. IT IS STRONGLY URGED THAT THE CUSTOMER STUDIES THE ACT BEFORE OPERATING THE SHEAR. THE ACT REQUIRES THAT THE PERSON OPERATING THE SHEAR WEARS GOGGLES, GLOVES, APRON AND PROTECTIVE FOOTWEAR. ENSURE THAT THE AREA AROUND THE MACHINE IS CLEAR. PRACTISE CONTROLS BEFORE CUTTING. DO NOT ATTEMPT TO SHEAR: ENCLOSED VESSELS, CYLINDERS, GAS BOTTLES, ETC. EXPLOSIVE. VOLATILE OR ACID MATERIALS, HARDENED STEEL PINS OR PARTS. g) After setting up the machine, practice the controls. Become accustomed to the feel of how it responds with different pressures on the foot pedal and how the head returns to a safe position as soon as the foot is removed from the pedal. Make sure the pedal is adjusted properly. (See paragraph d)). Make sure that the pedal isnot obstructed in any way (i.e.pieces of material not allowing it tobe fully depressed) or that the cable is not bent or damaged in any way, these points are most important for the correct control and functioning of the shear! FILED: KINGS COUNTY CLERK 02/03/2021 12:25 PM INDEX NO. 523006/2020 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 02/03/2021 h) Stroke Adjuster. The stroke of the head can be shortened to suit the type of work at hand. This is done be repositioning the sliding clamp on the stroke rod which is mounted alongside the rain. (see Fig. I items 8&9) To shorten the stroke start machine and take the head down to the required opening position. Switch off machine, slacken the thumbscrew on the adjuster, and slide the block up to contact the end of the stroke cylinder. Retighten the thumbscrew. Lengthening the stroke is the same procedure but the adjuster is- moved down the.. ro.d .away~ from the stroke. cylinder. i) Metal cleaning and cropping. Position the foot pedal for the most comfortable operating stance, in front or. just offset: from the blades. Use a bin or tray to collect cleaned materials. Try where possible to locate the work in one of the blade notches. Bring the top blade down onto the- work then gently crack through. When holding material in the ja