FEATURE MACHINE BUILDING, FRAMEWORKS & SAFETY
THE IMPORTANCE OF CE/UKCA MARKING
When building machines, it is vital to ensure that the CE/UKCA marking is considered from the start to prevent
common problems occurring, as Paul Taylor, head of Industrial Products (UK) at TÜV SÜD, explains
W
hile all machines supplied in the European Economic Area must
comply with the Machinery Directive, machinery end-users must also take into consideration The Work Equipment Directive. In the UK, this is implemented by the Provision and Use of Work Equipment Regulations 1998 (PUWER). When PUWER first came into force, to
TAKING AN EFFECTIVE APPROACH When building machines, or when combining machines to produce an assembly of machines, it is easy to get things wrong and end up with a project that requires a lot of rework and ends up going over budget or over time. To this end, it is vital to ensure that the CE/UKCA marking is considered from the start. If this isn’t done, common problems that occur include: • Equipment being installed before a final layout is agreed so that machines have to be moved and rework is required.
• Consideration not given to a safety related control system at the start, leading to a number of problems when linking different machines with different performance levels.
• Not considering control system functionality so that feed conveyors are not stopped when a process is stopped, resulting in damaged products at best and, at worst, injury.
When building machines, or when combining machines to produce an assembly of machines, it is easy to get things wrong and end up with a project that requires a lot of rework and ends up going over budget or overtime. To this end, it is vital to ensure that the CE/UKCA marking is considered from the start
presume conformity the end-user was only required to check that equipment carried a CE Marking. Since then, PUWER has been updated and the onus is now on the end-user to make sure that the equipment complies with all relevant CE marking legislation. Although the UK has officially left the
EU, until the end of 2020 there will be no change to the process we currently apply for CE marking conformity. If UKCA marking does come into force, it will not be retrospectively applied. If the machine was CE marked before the end of 2020, this will still be the case and any further models will require the application of the UKCA marking process. As EU Directives are transposed into National Law, the UK already has a legal system in place that applies. While harmonised standards’ will change to ‘designated standards’, the actual standards will remain the same as EU harmonised standards, to maintain a single model. This will require the compilation of an approved list of designated standards for UKCA marking.
8 APRIL 2020 | DESIGN SOLUTIONS
• Machinery that is not inspected before installation subsequently reveals non- compliances, resulting in disagreements about who pays to put it right – the supplier, the contractor or the user.
• Control colours not being agreed so that different suppliers may use different colours, leading to confusion. The European Standard allows for green, white, black or grey for ‘start’ and red, white, black or grey for ‘stop’, so even if the supply chain complies with the standard, errors and confusion can occur. Equipment is often
designed and installed with no thought as to what happens either upstream or downstream, or who takes the responsibility for which parts, and who takes responsibility for the final assembly. This can be exacerbated when equipment is sourced from outside the
European Economic Area or existing equipment is linked to new equipment. When starting a project, it is therefore
important to know who is going to take the responsibility for the CE/UKCA marking and lay down the ground rules. Decide what Performance Level the machine will come under, using EN ISO 13849, and ensure all suppliers are aware of what is required. Make sure they all understand which EN Standards to follow, and that they have copies of the Standards. A good tip is to ask for sample declarations before deciding on suppliers, so that you can check to see if they contain the correct information.
TAKING RESPONSIBILITY When you issue purchase orders, ensure there is a clause about CE/UKCA marking which states whose responsibility it is. A solution to this is to use a User Requirement Specification (URS) when purchasing new equipment, which will outline your requirements for the equipment supplier. A URS should include statements such as: • The machine must comply with all applicable European and UK legislation (list all applicable directives)
• Euro-norm standards should be used to achieve compliance with the essential safety requirements of all applicable directives
• Documentary evidence demonstrating compliance with all applicable directives will be required
• A Declaration of Conformity will be required
• A CE/UKCA marking will be applied to the machine, preferably on the maker’s nameplate
• A full operation and maintenance manual that complies with EHSR 1.7.4 of the Machinery Directive will be required. Before accepting and paying for any
machines, check that they meet the requirements of the order and also that they conform to the Machinery Directive. A pre-purchase audit is a useful system that can help machinery buyers ensure that equipment is both safe and correct.
TÜV SÜD
www.tuv-sud.co.uk
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