FEATURE HEALTH & SAFETY
EXPLODING THE MYTHS OF machinery CE marking
If the machine you purchase is CE marked is that proof of its safety? Neil Dyson, business line manager for machinery safety at TÜV SÜD Product Service explains why that is not the case
areas of guidance to help machinery end-users identify if the modifications they have made will be considered substantial by the regulatory authorities. The Health & Safety Executive (HSE)
A risk assessment should be completed before new machinery is put into operation
W
idely accepted misconceptions about CE machinery marking in UK
industry means that while it appears to be one of the most simple EU requirements to get right it is one of the most misunderstood. For example, it is quite common for those purchasing machinery to assume that if it has CE marking no further action on their part is required. However, CE marking is not proof of machinery safety. By applying the CE marking and
providing the associated EU Declaration of Conformity (DoC) a manufacturer or importer of machinery is confirming that a machine meets the requirements of all applicable EU Directives. It is therefore essential that machinery end-users understand their supplier’s responsibility in order to ensure compliance with machinery CE marking requirements. The DoC is a formal statement that a
machine complies with applicable directives and standards. It must be signed by the responsible person within the organisation who may be subject to prosecution if the equipment is found not to comply. The DoC must include: ● Name and address of manufacturer (or their authorised representative) ● Description of product including type, model - any information that clearly relates the equipment to the Declaration ● Reference to the standards applied ● Identification of the signatory An essential element in demonstrating that CE marking requirements have been met is the production of a technical
16 OCTOBER 2015 | FACTORY EQUIPMENT
construction file (TCF) which must conform to the provisions set out in the Machinery Directive. Annex VII paragraph 1(a) states that the TCF must include ‘documentation on risk assessment’ demonstrating the procedure followed: i. list of essential health and safety requirements (EHSRs) which apply to the machinery ii. description of protective measures implemented to eliminate identified hazards or reduce risks and when appropriate the indication of the residual risks associated with the machinery. EHSR 1.1.2 says: “machinery must be
designed and constructed so that it is fitted for its function taking into account foreseeable
misuse...the aim of measures taken must be to eliminate any risk throughout the foreseeable lifetime of the machinery”. A risk assessment should be completed
before new machinery is put into operation. Software has been designed for machinery compliance risk management; it is essential that it is the latest version that reflects current legislation.
MAKING CHANGES
Any substantial changes to machinery such as upgrades or if it is interlinked with other equipment as part of an assembly may make the existing DoC invalid. This could necessitate a new conformity assessment even if the machinery was originally compliant with CE marking when it was first purchased and put into service. There are two key
outline situations involving modifications to machinery where the requirements of the Machinery Directive are likely to apply and action must be taken: ● Machinery is modified so much that it should be considered as ‘new’ machinery. ● Machinery refurbishment with a different safety package. ● An existing assembly of machines is modified. ● Machinery modified before it is first put into service. The CEOC International document
Modification of Machinery in Service – Guide for Inspection gives clear 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, if machinery screwed to the floor is moved and modified at any time it ceases to be a fixed installation. It is therefore rare that something presumed to be a fixed installation actually is and we regularly see this misunderstanding when we make site visits. A best practice approach would be to err on the side of caution and conduct on site pre-compliance EMC tests for machinery, even if it could possibly fall within the fixed installation definition. While understanding how to apply all the standards and directives that could possibly be relevant to your machinery is complex it is essential to get right to ensure that the CE marking is correctly applied. Without it machinery owners could be prosecuted or their employees injured by non-compliant machinery.
TÜV SÜD Product Service T: 01489 558100
www.tuv-sud.co.uk
/ FACTORYEQUIPMENT
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