New HSE advice on CE marking assemblies of machinery

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!

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Acknowledgements: machineb​uil​ing​.net – Used with per­mis­sion.
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Author: Doug Nix

+DougNix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. ( 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.

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