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New HSE advice on CE marking assemblies of machinery

2012 July 16
Guarded machinery in a plant

This post was orig­i­nally pub­lished on machineb​uild​ing​.net. Reprinted with permission.

By Jon Severn, machineb​uild​ing​.net

Guarded machinery in a plantA degree of con­fu­sion sur­rounds the ques­tion of CE mark­ing assem­blies of machin­ery under the Machinery Directive 2006/​42/​EC. To help clar­ify the sit­u­a­tion, the HSE (Health and Safety Executive) has pub­lished a new page on its web­site enti­tledIn situ man­u­fac­ture or assem­bly of work equip­ment and plant. This con­tains plenty of use­ful infor­ma­tion for machine builders, sys­tem inte­gra­tors, line builders and end users. Without wish­ing to repeat the con­tents in their entirety, the fol­low­ing high­lights some of the more impor­tant points relat­ing to assem­blies of machin­ery and the addi­tion of new machin­ery to exist­ing assemblies.

What is an ‘assem­bly of machinery’?

As the HSE web page explains, an assem­bly of machines must be CE marked as a whole when indi­vid­ual machines are linked in order to per­form a com­mon func­tion, when those machines are inter­con­nected so that an indi­vid­ual machine (or ele­ment) affects the oper­a­tion of oth­ers such that the whole needs to be risk-​​assessed, and when there is a com­mon con­trol sys­tem for the con­stituent units. On the other hand, if the con­nected machines func­tion inde­pen­dently, this is not con­sid­ered to be an assem­bly of machines for the pur­pose of CE mark­ing to the Machinery Directive.

What about an entire plant?

The HSE says that a com­plete indus­trial plant com­pris­ing many indi­vid­ual machines, assem­blies of machines and other equip­ment should be treated as sep­a­rate sec­tions, with any risks at the inter­faces cov­ered by instal­la­tion instructions.

The respon­si­ble ‘manufacturer’

Assemblies of machines must be CE marked as a whole by the respon­si­ble ‘man­u­fac­turer’ – which might be the sys­tem inte­gra­tor, line builder or end user, whether or not they have man­u­fac­tured the con­stituent units. If the indi­vid­ual units are capa­ble of oper­at­ing inde­pen­dently then they should be CE marked and be accom­pa­nied by a Declaration of Conformity (DoC); if they are placed on the mar­ket as partly com­pleted machin­ery (intended for incor­po­ra­tion within an assem­bly of machin­ery, for exam­ple), then they should not be CE marked but they should be accom­pa­nied by a Declaration of Incorporation (Dol) and assem­bly instructions.

Extent of responsibilities

According to the HSE, a ‘man­u­fac­turer’ who is cre­at­ing an assem­bly of machines is not respon­si­ble for the design of the indi­vid­ual machines and partly com­pleted machines, pro­vided the ‘man­u­fac­turer’ has checked that the equip­ment came with a DoC or Dol and ade­quate instruc­tions (cov­er­ing instal­la­tion, oper­a­tion, main­te­nance, etc), is CE marked where appro­pri­ate, and is free from ‘obvi­ous’ defects (the HSE gives the exam­ple of dam­aged or miss­ing guards).

Adding new machin­ery to old assemblies

So far we have con­sid­ered only new assem­blies of machin­ery, but the HSE web page for In Situ Manufacture also addresses the ques­tion of assem­blies com­pris­ing new and exist­ing machin­ery – as might be the case when a line is being mod­i­fied, upgraded or extended. Whether or not the whole assem­bly needs to be reassessed under the Machinery Directive will depend on ta num­ber of fac­tors, so the HSE directs read­ers to the European Commission’s offi­cial Guide to the Machinery Directive 2006/​42/​EC. However, the HSE’s new web page does state ‘where a new machine is added to an assem­bly you do not have to re-​​asses those other machines in the assem­bly which are not affected in any way.’ Having said that, bear in mind that employ­ers have cer­tain duties under the Provision and Use of Work Equipment Regulations (PUWER), which may have impli­ca­tions for older machin­ery whether or not it is being modified.

More infor­ma­tion is avail­able on the HSE web­site, in the EC’s offi­cial Guide to the Machinery Directive, and in var­i­ous machin­ery safety guides and White Papers pub­lished by Procter Machine Guarding.

Thanks to Jonathan Severn at machineb​uild​ing​.net!

Post By Doug Nix (95 Posts)

+DougNix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. (http://​www​.com​pli​an​cein​sight​.ca) in Kitchener, Ontario, and is Lead Author and Managing Editor of the Machinery Safety 101 blog.

Doug’s work includes teach­ing machin­ery risk assess­ment tech­niques pri­vately and through Conestoga College Institute of Technology and Advanced Learning in Kitchener, Ontario, as well as pro­vid­ing tech­ni­cal ser­vices and train­ing pro­grams to clients related to risk assess­ment, indus­trial machin­ery safety, safety-​​related con­trol sys­tem inte­gra­tion and reli­a­bil­ity, laser safety and reg­u­la­tory conformity.

Website: → Compliance inSight Consulting Inc.

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