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Anderson8  
#1 Posted : 31 August 2011 08:49:20(UTC)
Rank: Forum user
Anderson8

Hi all,

Has anyone got any experience with installing large scale production line comprising of a number of pieces of equipment? Looking for some advice.

I understand PUWER regs 11 - 24 and assessment before and after installation to control this. However what does often give me a head ache is CE compliance. I understand this is the supplier who attached this and provides a deceleration of conformity, and all the stuff we understand about CE marking is only the manufactures declaration it is "safe". And I also get the machine parts, or machines designed to be integrated in to other machines will have a deceleration of incorporation.......fine with all that.

However, what I am unsure of is do we need to CE mark the complete line afterwards? And if so where can I find supporting information on this. In practical terms I am unsure of the benefits of this, so don't want to waste time and resources if our risk assessment of the complete line will cover this........Help please guys, any supply law, and machine experts out there, thanks ;-/

Sean
bibman  
#2 Posted : 31 August 2011 11:52:54(UTC)
Rank: Forum user
bibman

If each individual machine has been CE marked you will need to assess the interfaces between each and then CE mark the complete process.

See

Supply of Machinery Safety Regulations
European Commission - Guide to application of machinery directive 2006/42/EC
David Bannister  
#3 Posted : 31 August 2011 15:30:37(UTC)
Rank: Super forum user
David Bannister

It is my (layman's) understanding that CE marks are required for products being "put on the market". Thus if the line is being installed in your own premises for your own use then CE marking does not apply.

Of course, the entire line must still be subject to a rigorous risk assessment process and any significant exposures must be controlled.

I am happy to stand corrected on this by anyone who has definite information to the contrary.

David Bannister  
#4 Posted : 31 August 2011 15:37:44(UTC)
Rank: Super forum user
David Bannister

Forgot to include "by you" between "...installed "and in your own..."
paul.skyrme  
#5 Posted : 31 August 2011 19:35:56(UTC)
Rank: Super forum user
paul.skyrme

stuff,
The legislation for CE does not make the same distinction you do unfortunately!!!
It could make sense to do this as you are "maker" and "end user" so you have to comply with PUWER so it "should" be OK!
Mind one of the checks for PUWER compliance is CE!

Anyway, Anderson8,
Unfortunately you may well need to CE the line!
It is not quite as simple as I wish it were.
Please PM & I can pass on some further commercial info if you wish.
Not my services, but those of a specialist I have used in the past for machinery CE marking.
Betta Spenden  
#6 Posted : 31 August 2011 22:08:07(UTC)
Rank: Super forum user
Betta Spenden

Anderson8 wrote:
Hi all,

Has anyone got any experience with installing large scale production line comprising of a number of pieces of equipment? Looking for some advice.

Yes. And just to throw a curve ball in, the CDMR also applied in my case.
paul.skyrme  
#7 Posted : 31 August 2011 22:37:56(UTC)
Rank: Super forum user
paul.skyrme

Betta,
I would expect CDM to apply in all such cases!
Cuttell35960  
#8 Posted : 01 September 2011 05:59:33(UTC)
Rank: New forum user
Cuttell35960

Please note from my experience, CE stands for "CHECK EVERYTHING"

Start with the basics from PUWER such as the Emergency stops (do they work, are they in the correct place, do they over-ride every other control, etc), work through the controls of the machine as an individual section and part of the full line. From this, you will be able to have a pretty good idea for your RA's and SSOW as in some cases, isolation may not be possible when doing a cleaning process, un-jamming the machine, clearing blockages etc
bibman  
#9 Posted : 01 September 2011 11:17:16(UTC)
Rank: Forum user
bibman

I have to disagree with stuff4blokes.

My interpretation of the Directive is that CE marking applies even if the machinery is intended for own use.

Regulation 11(3) (as amended)
states that “(a) where a person being the manufacturer of relevant machinery, himself puts that relevant machinery or relevant component into service in the course of business; or (b) where a person, having imported relevant machinery from a country or territory outside the European Economic Area himself puts that relevant machinery into service in the course of a business, for the purposes of these Regulations that person shall be deemed to have supplied that relevant machinery to himself, compliance with the Regulations will be necessary.”
Anderson8  
#10 Posted : 05 September 2011 09:51:07(UTC)
Rank: Forum user
Anderson8

Hi all,

Many thanks for your response to this question, and a tricky question at that I have to say.

Having researched this I am fairly confidant we do need to apply CE to the line as a whole, I totally understand the risk assessment side of this some of you guys have touched on, so fine with that area thanks, and of course other regulations go without saying ie CDM as mentioned in here also, so no problems there.

It really is just the CE application to the line as a whole to support reg 10 puwer and the machinery directive which was giving me a headache guys.

paul.skyrme we have also used specialists for this process, will drop you a PM on this point, thanks for the info cheers.
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