Machinery Safety 101

New HSE advice on CE marking assemblies of machinery

This post was ori­gin­ally pub­lished on machinebuilding.net. Reprin­ted with per­mis­sion.

By Jon Severn, machinebuilding.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 machinebuilding.net!

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Acknow­ledge­ments: machinebuiling.net – Used with per­mis­sion.
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