New HSE advice on CE marking assemblies of machinery

Guarded machinery in a plant

This post was orig­i­nal­ly pub­lished on Reprint­ed with per­mis­sion.

By Jon Sev­ern,

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!

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Author: Doug Nix

Doug Nix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. ( in Kitchener, Ontario, and is Lead Author and Senior 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. For more see Doug's LinkedIn profile.