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Opinion CE Marking On your marks...

New EU legislation concerning industrial doors could lull warehouse operators into a false sense of security and compromise safety, warns Hörmann’s Alan Jenkins.

For some

time there has been consider- able confusion

over CE marking of industrial doors and what this means for the warehouse operator and owner. This is partly caused by manual and automatic doors falling under different directives. Manual doors are covered by the Construction Products Direc- tive while automatic doors are under the Machinery Directive.

vide the correct documentation, the original CE marking may well give the owner or operator the impression that the complete automated door is fit for purpose and covered by their insurance. In the first case, it must be stressed that CE marking does not signify that a product is fit for purpose; it simply means it complies with essential health and safety requirements of the Eu- ropean single market legislation. A product could therefore be

“Manual doors will be subject to [legislation] that will make it a criminal offence to place a construction product on the market anywhere in the EEA without a CE mark”

From 1st July 2013 this will change, when all doors intended for installation in a building – and for which a harmonised EN standard exists – become subject to the European Construction Products Regulation (CPR). This will make it a criminal offence to place a construction product on the market anywhere in the EEA without a CE mark.


While manual doors and powered doors supplied as a complete set will be CE marked, there is still a complication. If an installer sources a door and powered operator independently they are deemed to be the manu- facturer of the completed door and need to CE mark the whole assembly as a new door. In this case, if the installer does not pro-

52 May 2012 Storage Handling Distribution

CE marked yet not be suit- able for the use it is put to. The concern for the logistics industry will be in the event of injury where they could be deemed liable if the correct procedure is not followed. The Health and Safety Executive has issued guidance for industrial doors, since it considers them to pose particular health and safety risks and have been the cause of a number of serious and fatal accidents. HSE points out that where a door is modified or refurbished and this results in significant changes to the the control or operation of the door, then it will have to be CE marked by the person undertaking the modifications. To apply the mark, the installer must create a “technical file” and issue a declaration of conformity. The technical file protects both

the installer and end user, since it is proof that the door and op- erator are compatible and have been fitted correctly. If this com- bination of door and operator have been type tested by either manufacturer, they will be able to supply documents to support this. Alternatively, documentary proof that the specifications of the two components are compat- ible and suitable will suffice. Should the installer make struc- tural modification to the door, or any changes that may require further risk assessment, then the installer will have sole respon- sibility to create the technical file and CE mark the product.


The key point is to make sure that safety is not compromised. The simple solution is to source all the components from a single supplier who has already “type- tested” the operators and doors, to ensure compliance with the highest applicable standards. In this case, where the manu- facturer supplies the powered door as a ready-to-assemble kit, then it can apply the CE mark. When it comes to repair and maintenance, replacing com- ponents on a like-for-like basis will not require any additional paperwork. However, where components are replaced or modified, it will pay to check that the correct procedure has been followed and that genuine “type tested” products are supplied. n

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