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STANDARDS & DIRECTIVES
FEATURE
204: WHICH SHOULD YOU CONTROL PANELS?
the panel will require UKCA/CE marking according to the low voltage and/or EMC regulations/directives.
DESIGNATED/HARMONISED STANDARDS The simplest way to demonstrate compliance with the relevant essential requirements of the regulations and directives is to comply with the applicable designated/harmonised standards for the British/European markets. These standards provide a ‘presumption of conformity’. Earlier, we mentioned the 61439 and 60204 series of standards, so which parts of these standards are designated/harmonised to which regulations/directives? The table below provides a summary:
series of standards. In some cases, therefore, it may be appropriate to design, manufacture and install a machine control panel in compliance with specific clauses or subclauses of the relevant Parts of BS EN 61439. But (and it is a very big ‘but’) complying with 61439 does not mean 60204 can be ignored. Panel builders, system integrators and machine builders often seem to be familiar with the 61439 series and therefore apply it, but they are oblivious to the existence of the 60204 series. This situation is potentially dangerous because the 60204 series of machinery safety standards have been drafted to reduce the risk of injury to machine users and maintainers. If BS EN 60204-1 and other relevant Parts are not complied with, there could be risks such as electric shock and
Regulation/Directive
Standard (BS EN/IEC)
61439-1 61439-2 61439-3 61439-4 61439-5 61439-6 61439-7 61439-0 60204-1 60204-11 60204-31 60204-32 60204-33 60204-34
Machinery
No No No No No No No No Yes Yes Yes Yes Yes No
This table illustrates that the BS EN 61439 series is not designated/harmonised to the GB Supply of Machinery (Safety) Regulations or the European Machinery Directive. No part provides a presumption of conformity with the essential requirements. However, BS EN 60204 Parts 1, 11, 31, 32 and 33 are designated/harmonised and should be complied with as appropriate when a machine is UKCA/CE marked to the Supply of Machinery (Safety) Regulations or Machinery Directive. A machine can only be CE marked as a whole, including the control panel, so the control panel should be designed, manufactured and installed according to the relevant parts of BS EN 60204. Note that it is not mandatory to comply with designated/harmonised standards, but doing so is likely to be the most expedient way of meeting the essential requirements of the regulations/directives.
61439 VS 60204
Depending on the machine, the components it incorporates and the operating conditions, it may need to comply with some aspects of the 61439
Low voltage
Yes Yes Yes Yes Yes Yes No No Yes No No Yes No No
EMC
Yes Yes Yes Yes Yes Yes No No No No Yes No No No
overheating of cabling and components, resulting in a fire that puts lives at risk. Even if non- compliance does not cause injury, it can still give rise to unreliability, premature failures and unplanned downtime that can be very costly for the end-user. The supplier’s profitability suffers when the machine is still under warranty. Those panel builders and others familiar with the 60204 series do not find compliance expensive or time-consuming. Compliance can save time and cost; for example, correct labelling of terminals and wiring can speed commissioning and fault-finding.
BENEFITS OF COMPLIANCE Complying with the standard during the design,
manufacture and installation costs far less than undertaking rework. In addition, a machine that is fully compliant with BS EN 60204-1 is less likely to give rise to problems when a customer conducts a pre-delivery UKCA/CE marking audit. Moreover, last-minute rectification can also jeopardise delivery dates. Typically, machine control panels should
comply with BS EN 60204-1 and maybe one of the other Parts if appropriate. In addition, some clauses and subclauses of BS EN 61439-1 and BS EN 61439-2, may also need consideration. It is vital that the documentation presents the rationale behind which aspects of BS EN 61439 have been applied and which have not, and a formal risk assessment plays a significant role in informing this rationale.
EXPORTING TO THE EU Panel builders that design and manufacture panels for the EU market – or other regions where the European Low Voltage Directive and EMC Directive have been implemented – are likely to need to CE mark the panels. In addition, the panel builder needs to have an economic operator based in the EU so they can comply with EU Regulation 2019/1020 on market surveillance. In most cases, the best option is to appoint an EU Authorised Representative (EUAR). Similarly, if machine builders are exporting to the EU, the machinery needs to be CE marked in accordance with the EU Machinery Directive. Not only do GB machine builders need to follow the CE marking process, but they must also name somebody on the Declaration of Conformity (DoC) who is authorised to compile the technical file. This person must be established in the EU, which can be problematic for many GB-based machine builders. Fortunately, Safe Machine has a sister
company based in the Republic of Ireland, Hold Tech Files. This company can act as an EUAR and can be named on a machine’s DoC. This is all managed via a simple web-based portal where clients can sign a mandate, pay a fee and upload the relevant files to a secure server. The Machinery Directive is being superseded by the new Machinery Regulation in 2027. One of the many changes is that the Machinery Regulation is more specific about the requirements in relation to economic operators.
Safe Machine
www.safemachine.co.uk
To support companies working with BS EN 60204-1, the late Paul Skyrme and Derek Coulson have jointly authored a white paper, 'BS EN 60204-1 for machine builders and panel builders – a guide to avoiding common errors'. This document presents approximately 80 ways in which this standard's requirements are often not met. For a free copy of this white paper, email
derek@safemachine.co.uk or download it via this link:
https://www.safemachine.co.uk/wp-content/uploads/2024/04/SM-White-Paper-@A4-Apr-24-1.pdf.
MAY 2024 DESIGN SOLUTIONS 49
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