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MACHINERY & MACHINE SAFETY


parts can comply with the same conformity assessment requirements that were in place at the time the original product or system they are ultimately intended to repair, replace or maintain, was placed on the market.


FIXED INSTALLATIONS While a single item of equipment might meet these limits, there is no guarantee if you combine multiple items or additional components, that for example, the overall emission levels will still be satisfactory. Therefore, the final integrated product must be assessed against EMC standards. A word of caution is that large installations


may fall under the definition of a fixed installation, as Article 3 in the Machinery 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


By Ian Wright, chief engineer at TÜV SÜD


normal at all times and applies to tests for continuous EMC phenomena (like immunity to adjacent mobile phones). Criteria B allows some degradation during the test condition and applies to tests for transient immunity (infrequent events, such as electrostatic discharge due to someone touching the equipment). Criteria C allows temporary loss of function and applies to severe transient immunity which is very infrequent, such as a power surge or supply voltage interruptions. Permanent loss of function will be a failure. The machinery manufacturer must also have


a relevant conformity assessment procedure carried out and technical documentation drawn up. Once this is completed, the manufacturer is also required to draw up a declaration of conformity. Any technical documentation and the declaration of conformity must be kept by the manufacturer for 10 years after the machinery was first placed on the GB market. The UKCA 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 or the UKCA marking to the machinery, this information can be placed on the packaging and the accompanying documents. Any instructions must also be supplied in English. 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 with the 2016 Regulations. They must therefore take account of any changes in electrical equipment design or characteristics, and any change to a relevant harmonised standard or any technical specifications which are referred to in the Declaration of 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. This includes if the product is exported for repair. Any new spare


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). 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. UK regulations define a responsible person 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. 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 components, machines or the installation conform to the EMC requirements, machine builders must prove compatibility by way of EMC testing. While EMC may appear to be complex, it does not mean that machinery manufacturers can ignore their legal obligation to ensure their products meet the requirements of the 2016 Regulations. Neither should machinery end- users plead ignorance, making the assumption that their supplier is doing the right thing.


TÜV SÜD www.tuvsud.com/uk


FACTORY&HANDLINGSOLUTIONS | MARCH 2024 41


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