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DS-FEB24-PG18_Layout 1 02/02/2024 11:12 Page 1


FEATURE MACHINE BUILDING, FRAMEWORKS & SAFETY E


lectromagnetic compatibility (EMC) testing measures the ability of equipment or systems to function satisfactorily in their


electromagnetic environment without introducing intolerable electromagnetic disturbance to anything in that environment. Third-party EMC tests and conformity assessments therefore help to ensure that a product maintains its desirable features when exposed to adverse conditions (immunity test) and does not cause undue interference (emission test). Such tests ensure that a machine, and its electrical or electronic components, meets the UK’s Electromagnetic Compatibility Regulations 2016. EMC is an issue that many designers and


manufacturers find complex and confusing, but that does not mean that they can ignore their legal obligation to ensure their machines meet requirements. Neither should those manufacturers integrating components into their final product plead ignorance, making the assumption that their supplier is doing the right thing. Machinery manufacturers must have a relevant


conformity assessment procedure carried out and technical documentation drawn up. The next step is to issue a declaration of conformity, which declares that the product is in conformity with the relevant statutory requirements applicable to the specific product. Any technical documentation and the declaration of conformity must be kept by the manufacturer for ten years after the machinery was first placed on the market. The CE (EU market) or UKCA (GB market)


marking must then be affixed to the machinery. The manufacturer must also label machinery with their name, registered trade name or registered trademark, a postal address, and the type batch or serial number. If it is not possible


to affix these details to the machinery, this information can be placed on the packaging and the accompanying documents. Over time, as adjustments are made to the


manufacturing process and new or updated components included within a machine, the manufacturer must ensure that procedures are in place for it to remain in conformity. However, products which are repaired, refurbished or exchanged without changing their original performance, purpose, or type, are not considered ‘new’ and therefore do not need to be recertified and remarked. While a single item of equipment might meet


these limits, there is no guarantee if you combine multiple items or additional components that the overall emission levels will still be satisfactory. Therefore, the final integrated product, or fixed installation, must be assessed against EMC standards. Large installations may also fall under the definition of a fixed installation, as Article 3 in the EU’s Machinery Directive, and under interpretation in the UK 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...’ A fixed installation must be installed,


applying good engineering practices and respecting the information on the intended use of its components, and meet the essential requirements. 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


sponsored by


service. A responsible person is defined as 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.


ManageMent plans


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 the components, machines or the installation conform to the EMC requirements, machine builders must prove compatibility by way of EMC testing. Consideration of EMC at the earliest stage in


the design process will help manufacturers to minimise test failures, and the time and cost for reworking their design and retesting. A product lifecycle review will also highlight any design measures required to maintain compliance. This will help manufacturers increase the return-on- investment that they get from their EMC testing, help to ensure that the EMC integrity of products lasts a lifetime and enhance a brand’s reputation for product reliability.


TÜV SÜD www.tuvsud.com/uk


Machinery


Manufacturer’s eMc obligations


Despite being a


complex issue, machinery manufacturers need to ensure their machines


meet EMC compatibility regulations. Ian Wright, chief engineer at


TÜV SÜD, comments 1 DESIGN SOLUTIONS FEBRUARY 2024 8


Feature


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