FEATURE MACHINE SAFETY
THE COMPLEXITY OF MACHINE ASSEMBLIES
affects the operation of the others, a risk assessment of the whole assembly is necessary. The risk assessment must cover the
suitability of the separate units for the safe operation of the entire assembly, and potential hazards resulting from the interaction between them. It must also cover any hazards that are not covered by the Declaration of Conformity, the Declaration of Incorporation and the assembly instructions for the individual units. These three document types must also be included within the machine assembly’s technical file. The machinery assembly must be
by Paul Taylor, head of industrial products at TÜV SÜD Product Service E
ven though individual machines may comply with the Machinery Directive,
when they become part of an assembly or production line, which links two or more machines, it is this entire assembly that is then considered to work as an integral whole and must therefore be CE marked as a new machine. Similarly, if modifications are carried out that alter the performance or function of a machine, or assembly of machines, this is considered to be creating an entirely new machine which warrants re-certification. The definition of assemblies of
machinery indicates that assemblies are arranged and controlled so that they function as an integral whole in order to achieve the same end. For a group of units of machinery or partly completed machinery to be considered as an assembly of machinery, all of these criteria must be fulfilled: • The constituent units are assembled together in order to carry out a common function, for example, the production of a given product; • the constituent units are functionally linked in such a way that the operation of each unit directly affects the operation of other units or of the assembly as a whole, so that a risk assessment is necessary for the whole assembly; • the constituent units have a common control system. A group of machines that are connected
26 AUGUST/SEPTEMBER 2018 | IRISH MANUFACTURING
to each other, but where each machine functions independently of the others is not considered as an assembly of machinery in the above sense. Under the Machinery Directive, the
system integrator/end user that has created the machine assembly from separate units is responsible for ensuring that the assembly complies with the Directive’s essential health and safety requirements. This is most likely the case, as it is common practice for manufacturers of separate machines to place them on the market as complete machinery, which could operate independently, or as partly completed machinery that will then be assembled into a larger unit. However, if the organisation buys the
entire assembly from an original manufacturer, it must bear the CE marking and be accompanied by a Declaration of Conformity. If machines are placed on the market as partly completed machinery, they should not have the CE marking applied, but must instead be accompanied by a Declaration of Incorporation and the assembly instructions. It is then the machinery system integrator/end-user’s responsibility to ensure compliance.
SAFETY If the constituent parts are functionally linked in such a way that each unit
If modifications are carried out that alter the performance or function of a machine, or assembly of machines, this is considered to be creating an entirely new machine which warrants re-certification
Below: Paul Taylor, head of industrial products at TÜV SÜD Product Service
designed and constructed in such a way that the stop controls, including the emergency stop devices, can stop not only the machinery itself but also all related equipment, if its continued operation may be dangerous. Where individual machines making up an installation are not linked together via a main control system, this would not be classed as an assembly of machines under the Machinery Directive.
MODIFICATION The technical file must document any modifications that have been made to the separate units, when incorporating them into the assembly. Also, during its lifetime, one or more units of an existing assembly may be replaced by new ones, or new units added to an existing assembly. For such machinery in service, under regulation 10 of PUWER*, the employer must ensure that the conformity and safety of the machinery is maintained throughout its working life. When a machine assembly is first
created, or later has substantial changes made, a full CE marking and Provision and Use of Work Equipment Regulations (PUWER) assessment must be completed before that machine can be returned to service. Creating a machine assembly can be a complex process, but guidelines from sources such as the Health and Safety Executive, as well as ensuring a thorough understanding of the Machinery Directive, should bring clarity. *This applies to NI and the rest of the
UK. In the Republic of Ireland, the Safety, Health and Welfare at Work Regulations, chapter two covers work equipment.
TÜV SÜD
www.tuv-sud.co.uk
/ IRISHMANUFACTURING
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