FEATURE MACHINE BUILDING, FRAMEWORKS & SAFETY
EMC tEsting of MaChinEs: why thErE’s no shortCut to aChiEving CoMplianCE
one who holds a position of sufficient responsibility to control the configuration of the fixed installation. However, they do not have to be an EMC expert as they are allowed to seek appropriate advice. We would therefore advise that an EMC
management or test plan is developed for any fixed installation, and machinery owners would be well advised to contractually require suppliers to submit technical documentation along with their sub systems. A management plan for larger installations
should specify the intended environment and a list of appropriate standards for suppliers at the outset. It should be noted that all commercially available equipment, which is part of the fixed installation, must be CE or UKCA marked – and should therefore have a declaration of conformity supported by technical documentation. If there is no means of identifying that the
Paul Taylor, head of industrial products (UK) at TÜV SÜD, examines Machinery Fixed Installations and EMC Best Practice
A
ll applicable machinery within the scope of the EU’s Machinery Directive and the UK’s Supply of Machinery
(Safety) Regulations 2008 must be designed and constructed to meet the requirements of the EMC Directive (2014/30/EU) and Electromagnetic Compatibility Regulations 2016, respectively. If a machine’s control system experiences
electromagnetic interference it may malfunction. Conversely, if the electrical and electronic systems fitted to a machine generate a high level of interference, it may cause other equipment nearby to malfunction. Machine builders therefore have a legal obligation to protect systems against electrical interference and meet EMC requirements. The essential requirements state that
equipment must be designed and manufactured to ensure that: a) The electromagnetic disturbance generated does not exceed the level above which radio and telecommunications equipment or other equipment cannot operate as intended.
b) It has a level of immunity to the electromagnetic disturbance to be expected in its intended use, which allows it to operate without unacceptable degradation of its intended use. There are, however, specific requirements for
fixed installations. A fixed installation is defined as ‘a particular combination of several types of
apparatus and, where applicable, other devices, which are assembled, installed and intended to be used permanently at a predefined location’. A word of caution is that
large installations may fall under the definition of a fixed installation, as Article 3 in the directive, and under interpretation in the regulations, includes the following definition: ‘…a particular combination of several types of apparatus, and, where applicable, other devices, which are assembled, installed and intended to be used permanently at a pre-defined location…’ The UK regulations include specific
essential requirements for fixed installations. A fixed installation must be installed applying good engineering practices and respect the information on the intended use of its components, and meet the essential requirements set out in points (a) and (b) above.
taking responsibility
All of this information must be documented and held by the designated ‘responsible person’, so that it can be made available to the enforcement authority at their request. Operators of fixed installations must identify the responsible person before it is taken into service. UK regulations define a responsible person as
30 DESIGN SOLUTIONS JULY/AUGUST 2021
components, machines or the installation conform to the EMC requirements, then machine builders must prove compatibility by way of EMC testing. This is reinforced by the following statement from the Health & Safety Executive: ‘Section 6 of the Health & Safety at Work
Act (HSAWA) places a duty on manufacturers to carry out or arrange for the carrying out of such testing and examination as may be necessary to ensure that the article is so designed and constructed that it will, as far as is reasonably practicable, be safe and without risks to health. In the context of EMC, in most applications it is the electromagnetic immunity of equipment for
the environment it is placed into that is of interest in relation to Section 6 of the HSW. If it is reasonably practicable to carry out testing for immunity to electromagnetic disturbances, the HSAWA requires this to be carried out’. Section 10 of the Provision and Use of Work
Equipment Regulations 1998 (PUWER) states that ‘every employer shall ensure that an item of work equipment has been designed and constructed in compliance with any essential requirements’. These two statements leave no room for
doubt about the necessity for EMC testing of machines – there is simply no shortcut to achieving compliance. Machinery owners must therefore ensure that the equipment which their employees use is EMC compliant to assure the safety of equipment. Manufacturers of machinery may also wish to consider the independent support of an EU Notified Body or UK Authorised Body to prove due diligence.
TÜV SÜD
www.tuvsud.com/uk
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