Rank: New forum user
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Hi, Im fairly new to all of this and the infomation I have read is fairly ambiguous so Im hoping someone may provide some clarity. I have some assembly machines for assembling Electronic PCB's that are linked together by conveyers which are controlled by SMEMA connections. Each machine operates independently of teh other and they are not controlled by one circuit, and do not need the others to operate. So I have a Paste machine that puts solder paste onto a PCB, next is a Pick and Place machine that places electrical components then an Inspectoion machine and finally a Reflow machine which forms the solder joint. All the conveyers do is receive a signal from the upstream machine to say its ready and send the next board. So in the above scenario do I need to have the machine CE marked as an Assembly of machines? Any help greatly appreciated.
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Rank: Super forum user
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Basically the CE Mark means that the item conforms to the requirements of directives that apply - are you a manufacturer
SBH
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Rank: New forum user
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Not a manufacturer of the equipment but yes we use the equipment to manfacture circuit boards. I should have said all the individual items of equipment are CE marked and they are from different manfacturers. We have created an assembly line with teh equipment so shoudl in be CE marked as an 'Assembly of Machines' according to the CE directive? This is where I cant find a definitive answer.
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Rank: Forum user
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Well, you have created a new machine from the constituent machines, and it is theoretically possible that you have created or altered some risks that were not considered by the manufacturers of the individual machines. Have you identified any uncontrolled risks in your risk assessment for the combined machine? The official guidance is at http://ec.europa.eu/grow...g/machinery/index_en.htm
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Rank: Super forum user
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But it doesn't sound from the description as if it is a new machine. It sounds like a series of unconnected machines that perform independent tasks in a sequence and are in physical proximity to each other just for the efficiency of manufacture. In which case it would seem that using individually CE marked machines is enough.
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Rank: Super forum user
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I would agree with Kate.
Sounds like separate machines feeding each other by conveyor belt systems. From the info we have, if each individual section of the manufacturing process is being fed components within its design range then the design intent doesn't seem to have changed.
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Rank: Super forum user
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Sorry guys the OP clearly states that they are linked by conveyors - IIMHO this changes things and as such the whole thing needs to be CE marked as a whole. If you have put in the conveyor to link individual machines then you have created a 'new' more complex machine and thus it should be CE marked. Stu
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Rank: Super forum user
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stuie wrote:Sorry guys the OP clearly states that they are linked by conveyors - IIMHO this changes things and as such the whole thing needs to be CE marked as a whole. If you have put in the conveyor to link individual machines then you have created a 'new' more complex machine and thus it should be CE marked. Stu
I agree. However if the individual machines do indeed comply (be aware thats nowhere near the same thing as marked!) the task is greatly simplified.
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Rank: Super forum user
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SBH wrote:Basically the CE Mark means that the item conforms to the requirements of directives that apply - are you a manufacturer
SBH Being cynical but experienced in such matters: the CE mark means I bought a bag of labels and stuck them on my products. The declaration and the technical file (assuming it contains the truth) documents compliance.
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Rank: Forum user
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The HSE add some clarity on this issue: http://www.hse.gov.uk/wo...manufacturer-in-situ.htmMy interpretation on it (and I'm not from a manufacturing background, so I may just be howling into the void) is that an "assembly of machines" is intended to capture complex collections of individual machines which are then linked via a common control system which sequences them. The system in the OP appears to be independent machines linked by conveyors. If the parts autoload into the next machine its an assembly. If the conveyors dump the parts into a bin to be manually loaded into the next "station" then it may not be. Is there also a question of who "manufactured" the assembly? Forgive my ignorance, but isn't CE marking required for trade/marketing of products (i.e. if the manufacturer is selling an item which falls under the directive it must be CE marked)? I was under the impression that CE marking was used to indicate conformity of a product so that it could be traded freely within the EU/beyond? On this basis, if the "assembly" is installed by a third party then it would need to be CE marked as a unit. If the component parts are connected in house and the assembly is not being "sold" per se, does CE marking still apply?
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Rank: Super forum user
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AD wrote: If the component parts are connected in house and the assembly is not being "sold" per se, does CE marking still apply?
You are "almost" right; it might be a simple job of building a techical file to demonstrate conformity and that you have not neutratised safety devices or introduced further hazards. There are a few paragraphs in PUWER that cover this. The difficult bit might be getting detail from the individual manufacturers. The actual CE mark is a red herring
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Rank: Forum user
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Quote: You are "almost" right; it might be a simple job of building a techical file to demonstrate conformity and that you have not neutratised safety devices or introduced further hazards. There are a few paragraphs in PUWER that cover this. The difficult bit might be getting detail from the individual manufacturers.
The actual CE mark is a red herring
That's useful, thanks. I was under the impression that machinery manufactured for the exclusive use of the manufacturer was potentially outside the scope of CE, per se, but would obviously still be subject to the various acts & regulations which it fell under (CE being a badge to demonstrate this to the market, which could only be attained if compliance with all of the actual legislation was in place).
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Rank: Forum user
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Evening All, If the components were sold individually, to then be incorporated into a machine/process, would they not have been issued with a declaration of incorporation? Article 13 -DIRECTIVE 2006/42/EC? http://eur-lex.europa.eu...042-20091215&from=ENMAT
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Rank: Forum user
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MAT, they should have been, if they were intended to be incorporated into a larger machine. On the other hand, if the user has combined several machines that were originally intended to function separately, then he is likely to have created a new machine. CE marking is a process, the affixing of the CE mark being just one stage in that process.
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Rank: Super forum user
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I’m late coming to this thread, sorry. Just a quick comment.
A series of machines connected together to operate as an assembly/integrated production line will require CE marking as a complete assembly even if the machines are issued with DoC’s. Why? 1st, if the equipment is issued with a DoI, then it needs further work and integration to be “safe”, so that’s an obvious one, “stuff” with DoI’s will need to be further CE marked and thus correctly assessed once integrated into the “whole”. Next if the equipment is issued with a DoC and needs no interlocking to other equipment, nor modification to be used by a person to undertake all operations, e.g. loading unloading etc. then it doesn’t need further assessment as the unit can be used fully standalone by a person or two without them being endangered in any way. Now if you have a series of machines & conveyors that are interconnected, could you physically separate them and put a person between the machine and the conveyor and use the person to safely receive the part from the machine and place it onto the conveyor, and another person to safely take the part from the other end of the conveyor and safely load it into the machine without ANY modifications to ANY of the equipment. If yes, then no further action. If no, then you need to certify the line. From your OP I would say you need to certify the line. Plus you say the equipment is interfaced with SMEMA connections. Now these are signal interfaces on two levels, a ready & board present signal, and a communications interface down which M2M comms is sent, so I would again say that if you are using the SMEMA interface then you have a complex assembly. Thus it requires assessment as a whole. As far as the linking via a common control system is concerned, this is not the requirement to trigger a whole line assessment. A common control system would in itself trigger a whole line assessment, but, there are other things. As you have SMEMA interfaced machines then it could be argued that you have a common control system because if you unplug the SMEMA connectors, I bet the line stops!
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