Preview
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