FEATURE Machine Building & Frameworks
Proving machinery compliance By Paul Taylor, Head of Industrial Products (UK) at TÜV SÜD, a global product testing and certification organisation N
ow that the UK has left the EU, machinery users will slowly start to see a UKCA mark appearing on compliant
products. However, procedures have changed very little from the EU’s CE marking structure. In both jurisdictions the same rules will apply for designers, manufacturers and importers – everyone must understand their legal duties and responsibilities. It is therefore vital that machinery users are aware of what their suppliers should be doing. Neither the CE nor the UKCA marking can be applied unless a machine meets the requirements of the Machinery Directive in the EU or the Supply of Machinery Regulation 2008 in the UK, as well as any other applicable directives. The CE/UKCA marking involves a four-step process: 1) Essential Health & Safety Requirements (EHSRs);
2) Technical Construction File; 3) Declaration of Conformity; 4) Affi x the CE/UKCA Marking. Machinery must satisfy the EHSRs for any corresponding hazard which may apply to it. The EHSR requirements are wide-ranging, taking into account potential dangers to operators and other persons who may be at risk. A typical example of an EHSR is the requirement to provide adequate warning labels where there are moving parts that might trap parts of the body of personnel using the machine. Another would be the requirement to provide safety guards to machine tools. However, taking into account the state of the art, it may not be possible to meet all the objectives set by EHSRs, as technologies often move more quickly than the standards trying to catch up with them. With this in mind, the machinery must be designed and constructed with the purpose of approaching these objectives. The Declaration of Conformity must accompany every machine placed on the market. This is the manufacturer’s assurance that the product complies with the applicable directives. It must carry relevant product information and be signed by a responsible person on behalf of the manufacturer or importer. The alternative to a Declaration
18 March 2021 | Automation
The technical construction file proves due diligence and provides evidence of compliance, so it’s the first document that the authorities will ask for
of Conformity is a Declaration of Incorporation. This applies to partly- completed machinery that is intended to be part of an assembly but cannot itself perform a specifi c application. This declaration and assembly instructions for the partly-completed machinery will then form part of the technical fi le for the fi nal machinery assembly.
Essential elements The technical construction fi le proves due diligence and provides evidence of compliance. It is therefore the fi rst document that the authorities will ask for, since it provides vital evidence that the correct procedures have been taken during product development. The technical fi le must remain available for inspection by a competent national authority, such as the UK Health and Safety Executive, for a period of ten years. However, it does not have to include detailed information such as the sub-assemblies of the machine, unless a knowledge of them is essential for verifi cation and compliance with the EHSRs. The fi le should contain the following: • General description. • Machinery and control circuits drawing, descriptions to undersand operation.
• Detailed drawings, calculation notes, test results, certifi cates, etc., to check conformity with the EHSRs. • Risk assessment documentation demonstrating the procedure followed, including: o A list of the EHSRs which apply to the machinery. o Description of the protective
Now that the UK has left the EU, machinery end users will slowly start to see a UKCA mark appearing on compliant products
measures implemented to eliminate identifi ed hazards or to reduce risks and an indication of any associated residual risks.
• Standards and other technical specifi cations used.
• Any test technical reports. • Machinery instructions. • Declaration of incorporation for partly-completed machinery and relevant assembly instructions. • Relevant copies of the declarations of conformity of machinery or incorporated products.
• Copy of the declaration of conformity: o For series manufacture – internal measures that will be implemented to ensure conformity.
o The manufacturer must research and test components, fi ttings or entire machinery to determine it can be put into service safely.
The technical fi le can be a paper or
electronic fi le with hyperlinks. It must also be kept up to date as the product is adapted, which means that the technical fi le cannot be put away and forgotten. The fi nal step to prove compliance of machinery is to affi x the CE marking to machines being sold in the EU and UKCA mark for those being placed on the UK market.
CONTACT:
TÜV SÜD
www.tuvsud.com/uk
automationmagazine.co.uk
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