35th Anniversary
HAZARDOUS AREAS & SAFETY FEATURE Going beyond confirming conformity
Neil Dyson, business line manager for Machinery Safety at TÜV SÜD Product Service, explains what machinery users should be doing to ensure their CE marked equipment continues to fulfil safety standards and directives
B
efore any item of machinery can be legally placed on the market in the
European Union (EU), it must bear the CE marking to show that it conforms to EU requirements. When manufacturers apply the CE marking to their equipment, and provide the associated Declaration of Conformity (DoC), they are confirming that the product meets the requirements of all relevant EU Directives and UK Regulations.
In our experience, many
machinery owners assume that if their equipment has the CE marking that no further action is required. However, CE marking is not proof of a machine’s safety, and is one of the most misunderstood requirements. As a machinery owner and end user, what should you be doing?
machinery, such as upgrades or if it is interlinked with other equipment as part of an assembly, could necessitate a new risk assessment, even if the machinery was originally compliant with CE marking when it was first in service. There are two key areas of guidance to
‘It’s vital you have an understanding of
what manufacturers must do to ensure that their machines comply with CE marking requirements’
help machinery end-users identify if the modifications they have made will be considered substantial by the regulatory authorities. The first is the Health & Safety Executive, which outlines the different situations involving modifications to machinery where the requirements of the Machinery Directive are likely to apply and the
action must be taken. A second reference guide is the
CEOC International document ‘Modification of
PROTECTING EMPLOYEES The Work Equipment Directive, which is implemented in the UK by the Provision and Use of Work Equipment Regulations 1998 (PUWER), applies to all equipment regardless of its age, including equipment that carries the CE marking. PUWER describes what an employer needs to do to protect employees in the workplace. It is the employer’s responsibility to ensure that all machinery meets the requirements of the Machinery Directive and PUWER. A thorough risk assessment should therefore be completed before any new machinery goes into operation. Problems can then be rectified with the manufacturer, so that they or the machinery owner no longer run the risk of a prosecution under the Machinery Directive or PUWER. Software has been designed for
machinery compliance risk management, taking much of this headache away. But, it is essential that the latest, most up to date version is used, to ensure that it reflects current legislation. Any significant modifications to
/ PROCESS&CONTROL
Machinery in Service – Guide for Inspection’, which offers guidance on what constitutes a ‘non substantial’ and a ‘substantial’ modification. In order to carry the CE marking and
comply with the Machinery Directive, any machine that has EMC sensitive electrical or electronic components must meet the requirements of the EMC Directive (2004/108/EC). The only machines that are not subject to conformity assessment with the essential requirements of the EMC Directive are fixed installations. However, it is rare that something that is presumed to be a fixed installation actually is and we regularly see this misunderstanding when we make site visits.
A thorough risk assessment must be completed before machinery goes into operation
To ensure that the machines you purchase comply in the first place, before they are installed at your premises, it’s vital that you have an understanding of what manufacturers must do to ensure that their machines comply with CE marking requirements.
Neil Dyson is business line manager for Machinery Safety at TÜV SÜD Product Service, a global product testing and certification organisation
SIGNED DoC A manufacturer’s DoC must be signed by the responsible person within the organisation, and that signatory may be subject to prosecution if the equipment is found not to comply. The DoC must include: • Name and address of the manufacturer (or their authorised representative) • Description of the product - including
type, model and any other information that clearly relates the equipment to the Declaration
When it comes to CE marked equipment, both machine manufacturers and machine owners have responsibilities
• Reference to the standards applied • Identification of the signatory The machine manufacturer must also produce a technical construction file (TCF), which must conform to the provisions set out in the Machinery Directive, and is an essential element in demonstrating that CE marking requirements have been met. Annex VII of the Machinery Directive states, in paragraph 1(a), that the TCF must include “documentation on risk assessment” demonstrating the procedure followed. The CE marking is a visible sign that a
machine complies with all the relevant standards and Directives. It is therefore essential that machinery owners understand both their responsibilities and those of their manufacturer, as required in the vast range of relevant standards and directives, in order to avoid injury or prosecution.
TÜV SÜD T: 01489 558100
www.tuv-sud.co.uk
Enter 210
PROCESS & CONTROL | JUNE 2015 13
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56