I apologise in advance but my expertise is in occupational not product safety:- We have been asked by one of our customers to source a product for them, but the product in question does not exist. Not being a company known to turn down a business opportunity, we have made up a prototype of the said product which they are interested in. The product is a very simple piece of steel box section, with a handle affixed, which acts as a lever to solve a common problem in the utilities industry. [When pipework is joined together, the coupling usually has a very small and "finicky" handle which is difficult to manouvre. Our product fits over this handle and acts as a lever, making the coupling process easier]. I have had a look at the tool and conducted a risk assessment on it - and it's usage - and all my reccomendations have been took on board (i.e. ergonomic handle, powder coating the metal, removal of sharp edges etc.) My question is this: What testing is necessary (i.e. legally required) before we supply this to our customers. Do the safety & supply machinery regs apply to a lever with no moving parts? Is a CE mark necessary? Hope I've painted an accurate picture. Regards, Ian

So if the SoM regulations don't apply (due to no moving parts) then does this just come under the general provisions of section 6? If it does, then these regulations do say that the manufacturer should ensure "the carrying out of such testing as is necessary". Has anyone any experience in this field? What testing is necessary before we produce and market a steel bar? Ian

I would take a pragmatic approach and examine its fitness for purpose. What are the maximum forces that will act on it? Where and how will it break or fail if the load exceeds it capability? What will happen as a result? This could lead to an examination of the basic design - shape and thickness of the parts the choice of material and the material properties any joints that have to be made - their design and integrity any stress concentrations that are created. You can potentially establish its safety from first principles, backed up by some destructive tests if needed.