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Posted By RL Michel
We have changed the control cabinet for one of our presses. The maintenance dpt wants to have a re-certification for CE marking for the group: press and cabinet, the production manager doesn't want to pay for it... and they want H&S, after evething has been decided, to impose the cost. I've just arrived in the company and found it like that.
The press manfacturer has filed for bankrupcy since, it was an italian company and it is still not clear who is taking care of their machineries. We relied on a local contractor, self-employed electrician to connect the control cabinet. Apparently, the maintenance dpt gave him the press files and he did the job.I don't know yet his status (registration/approved by ...)
Any thoughts?
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Posted By Sean Fraser
Tricky one this - which is probably why they gave it to you!
There are a number of factors to be considered here. Firstly, why are maintenance asking for CE Marking? How old is the equipment? Was it originally put in place on or after 31 December 1992 and so fall under the Supply of Machinery (Safety) Regs 1992? If previous to that, then it doesn't need CE marking unless it is being fully replaced.
Also - is the cabinet considered an integral part of the press or as separate? If separate, then it will come under the Regulations and so should have been CE marked itself, if intergral part then it is part of the assembly and will not need marked (although most new components should be separately CE marked anyway if they are destined for CE marked assemblies).
I would question the motivation behind chasing this re-certification - the CE Marking does not in itself make the equipment safe! However, it is possible to use a competent person to make an assessment of existing equipment to determine if it complies with SEP - Safe Engineering Practice - and of course type testing for pressure items conducted by a notified body would actually confirm the safety aspect of the equipment as it is being tested, not just assessed on it's design. This does allow CE marking to be applied retrospectively but this is optional, not a requirement. Unfortunately I'm not sure one defines the term "competent" in this case.
Obviously the equipment still needs to meet the general requirements of the Provision and Use of Work Equipment Regulations and a suitable Risk Assessment carried out on it's operation. Any new equipment must comply fully with the Regulations and this will include CE marking - but beware, some pressure items CANNOT be marked and so be careful not to have a blanket "The item must be CE Marked" in procurement conditions or incoming inspection.
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Posted By Stuart Nagle
As far as I am aware the following would apply:
1) either the press is, or is not 'CE' marked. if it is then the addition of a new control cabinet (which should be 'CE' marked) should, provided it has been conected in accordance with the instructions and inspected/approved as such, not require any further assessment to comply with the requirements.
2) If the press is not 'CE' marked (supplied prior to the requirements for 'CE' marking) it cannot be retrospectively 'CE' marked.
'CE' marking indicates that the item (and all of it's components) complies with all the respective standards applicable to that item (i.e. BS/ISO EN standards for the component parts and as a whole), and without going back over all of these, it would be almost impossible to retrospectively 'CE' mark the item.
3) If only the control cabinet is 'CE' marked and installed in accordance with the instructions, has been inspected and approved (by a competent person) then there is no further action needed for this - it is 'CE' marked and correctly installed.
Irrespective of this, if it is connected to a non 'CE' marked item, both cannot be 'CE' approved simply because the control cabinet is 'CE' marked, regardless of any inspection or approval of the control cabinet and irrespective of wether it is seperate or intergral to the press.
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Posted By RL Michel
We had initially an EC declaration of conformity and CE marking for the group (press and cabinet) from the manufacturer. My concern is that the new cabinet (CE marked) was added by someone not related with the manufacturer. What kind of qualification/competent person are we supposed to employ for this kind of job.
Considering only the hazards, the press is still the same. But PUWER, Reg.10 focuses on the machinery when it is first supplied. How are we supposed to act/justify the integrity of the machinery when we modify it, for example changing a mechanical guard for a light guard?
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Posted By Jim Walker
I think "CE mark", in your case, is a red herring.
When applying a CE mark all that is happening is that the manufacturer is declaring that the equipment complies to relevant standards.
What you need to do is identify those standards and get a competent person to verify the equipment (total installation really) complies. If not, you have a breach of PUWER.
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