OK here's one for the seriously knowledgeable Supply of Machinery and 'type approval' specialists out there.... First the background: A business operates a 360 tracked excavator. They have designed and had fabricated an attachment which (I suspect) is unique to their operations (similar to a demolition grab, but with significant industry-specific differences). The attachment, when used for its intended purpose in tests, proves to be versatile and useful, so the operator has several more fabricated and puts them into service... The tool is found to be extremely good at doing something it was not designed to do (and doing it very rapidly)... The tool is so successful that word gets around, and other businesses in the same industry begin to either request to purchase the attachments (from the originators of the idea) or to commission their own versions of the attachments. The problem is that the attachment can exert significant overturning moments on the excavator chassis. Overturn is currently prevented only by operator care and diligence. Where do I look for the standards applicable for type testing, for overload indicators, for tilt / stop limiters .... What should be fitted? At what stage must the operator (or whoever) undertake tests /technical file compilation and EC certification or whatever of the attachment - is it under the type approval system for the vehicle or under the supply etc regs 2008? If they're not selling any of the attachments - can they continue to use their own-design equipment? Supply regs and vehicle type approval have never been much in my spheres of interest, so I'm flundering in the annexes and parts and sub-parts of various bits of Euro jargon. And what other stuff should I know so that I (as a potential client) can ask the right questions? For the avoidance of any possible doubt - the operators are very aware of, and fully awake to, the risks - this is not a cowboy operation - but there could be significant cost implications in any CE marking / type approval process... And potentially there are mega buck contracts at stake if the potential problems can not be overcome successfully. So any supply etc or type approval etc specialists - if you know what you're talking about - I'd appreciate a steer in the right direction please... Cheers Steve

The "business" may already be in technical breach of Section 6(2) of HASAWA, which requires implementation of a risk reduction hierarchy & sfarp (eliminate or minimise....). Keeping this in-house is one thing, placing on the market under your own steam would be (IMHO) wholly inadvisable. Perhaps the best marketing strategy with your invention would be to strike a bargain with a 360 excavator builder and work together on effective controls. Early trip to register at the Patent Office might be advisable too.

Some key information links:- Machinery Directive - independent sources of advice:- http://webarchive.nation...v.uk/files/file54513.pdf Machinery - guidance notes on the UK regulations :- http://www.bis.gov.uk/files/file52968.pdf Full Suite of information on the Machinery Directive:- http://www.bis.gov.uk/po...ery-directive-2006-42-ec

Steve, Having had involvement in this process, it is my understanding that once the unit was "in production" for own use or sale, or where multiple units were produced to the same design for "own use" then Mach Dir & CE kicks in. You can be your own customer under this legislation. There are some experts I have used in the past I can put you in touch with if you want. HTH