"Obstacles to Digital DIY": some notes from Veneto
Following publication of "obstacles to Digital DIY in Greece", here is a similar report from our DiDIY Mini Tour in Veneto, to be read and used with the same constraints, namely:
- everything below is our synthesis from notes taken during many different email conversations and/or direct meetings, also before and after the "tour"
- these notes will be used as basis for our future work on DiDIY policy guidelines
- Before that, we hope that notes like these serve as starting point for similar discussions, online or in presence, with makers, teachers and other DiDIY stakeholders in all EU countries: we need your comments and input to be sure that we are considering all sides of each issue when writing those guidelines!
- As an additional note, we have to point out that some of the constraints described below may be specific of the Veneto Region, if not of the specific public tender under which certain fablabs were created in that region.
The "double soul" dilemma
On one side, [Fablabs in Veneto] are, and want to remain communities, or meeting points of other communities and NGOs. On the other, they are businesses that must sell services (training, on-demand fabrication, renting equipment..) to survive. Making these two souls coexist is crucial. But it is quite difficult to use any opportunity to ask for money, while maintaning, or promoting, the proposal of a fablab being above all a collaborative community.
Safety. Or burocracy?
- Italian regulations are very complex AND uncertain. This uncertainty forces fablabs, whenever there are several "classes of risk", to always comply with the obligations for the highest class. This can happen because:
- fablab owners feel obliged to do so to minimize expensive fines by officials who know nothing about fablabs, 3D printing, etc...
- or because the same officials, for the same reasons and to stay themselves on the safe side, explicitly ask fablab owners to apply rules for the most dangerous activities. Besides, officials in different towns or provinces of the same region give different interpretations of the same rules.
- In all cases, the end results are the same: fablabs must, on one side, spend on compliance with safety rules (which is not necessarily equivalent to actual safety) a lot of economic resources. On the other, they cannot make their members autonomous: a "safety officer" must always be present in the fabla, whenever a user wants to use any of the machines. Even if that user has been certified/trained to use those machines.
- Another way to summarize the general bureaucratic burden was "why does a 1 or 2 person company follow the same rules as one with (up to) 15 employees?"
- A very important point is that a lot of the burdens above, and in the rest of these notes, have little or nothing that is "DiDIY specific". As one of the people we met put it, "[we fablab/makerspace owners] have to attend the same safety/compliance courses as hairdressers, plumbers, etc; and they are just as overwhelmed and puzzled by rules and constraints that they find out of touch with reality as we are"
Equipment certification and documentation
Machines that are self-built, self-assembled or bought by small independent producers worldwide cannot have the CE marking https://ec.europa.eu/growth/single-market/ce-marking/index_en.htm But machines without that marking cannot be declared in the DVR ("Documento di Valutazione dei Rischi", i.e. Risk Evaluation Document"), and machines not declared in the DVR are not allowed in the fablab. A fablab can build a very sophisticated CNC machine, but cannot use it afterwards.
Certification procedures are long, expensive and not really compatible with non-mass produced equipment. Self certification requires, besides the time, paying for accessing the necessary documentation (even if certification is a public interest activity that should be fully transparent to everybody).
Other obstacles to use of DIY/not marked machinery is the fact that, by the letter of the law, every machine used in a "professional" setting should have full documentation, and user interface menus, if any, in the native language of its users.
No room left for the maker's attitude
- All existing norms written only for high-volume, full time production.
- Regulations on how to measure, filter and dispose of the emissions of hazardous substances, including sawdust or wood ashes, are conceived and written for production volumes much, much higher than what a fablab may ever reach, or want to reach. Again, the result is to stay non-compliant, spend too much money, or just give up on certain specific manufacturing activities... without any real safety-related reason to do it.
- In order to offer personal manufacturing services, or just rent the machines, the fablab owners must attend 3 courses: DVR/RSPP (Responsible of the Prevention and Protection Services), first aid and fire prevention course (because a designated First Aid/"Fire Fighter" should always be present in the fablab).
- The cost of such courses depends on the risk level associated to the activity which, as explained above, always ends up being the highest possible one
- Writing an adequate DVR is so complex, even for a fablab, that one would need to pay a specialized consultant to do it right.
- According to existing rules, certain machines should be kept in separate rooms.
The last point (as most of the previous ones..) goes completely against the philosophy that should power a fablab/makerspace, that is cooperation and peer to peer (self) training and support: such places should be open spaces, single environments in which people (potentially different people, every week!) learn from each other.
The absence of intermediate levels between hobby and fully professional production, only by professionals, also means that certain activities, like DIY design and manufacturing of drones for R&D purposes, are not allowed.
Limited interest from businesses
Many medium and small business would "use" fablabs much more if they could easily rent their equipment and technical support services to manufacture one-time prototypes, or special orders from their own customers. But this can only happen if a fablab has, and can advertise, a vast array of different machines with unique characteristics, which is something that is prevented from the problems above.
What about Education?
Certain teachers are still very cautious, when presented with the possibility of Digital DIY as a real mass phenomenon. This couple of comments is an adequate synthesis of this position:
- the are young people the best innovators? That's only half true: (much) more awareness is needed
- some authorization should be required to practice at least certain forms of digital DIY, and some way to control them too
On the other hand, teachers in Castelfranco Veneto told us that their students now know drones enough to see them as as general purpose butlers, not as mere "unmanned aerial vehicles" to take pictures, or video, from above. Their attitude is "I have this task to perform? Let's see how I could offload it to a drone".
Image source: the author's collection of drone picture