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Bazzer  
#1 Posted : 12 October 2016 15:57:02(UTC)
Rank: Forum user
Bazzer

A client has just had a CNC router installed; the machine was manufactured in the USA and installed by the UK supplier, and has been CE marked, and I've been informed a declaration of conformity has been issued (awaiting a copy). According to the supply of machinery regulations machine complies with the regulations.

Also I have other clients who have similar, but larger machines, that have guards fitted around the perimeter,and safety pressure mats to prevent the operator from approaching the cutter head, but the US machine only has emergency stops fitted.

Due to it being CE marked can I accept it meets the requirements of the Regulations

Ian Bell2  
#2 Posted : 12 October 2016 16:27:10(UTC)
Rank: Super forum user
Ian Bell2

CE marking is a little open to interpretation.

You should complete a PUWER assessment as well, if guarding is your concern, understand Reg11 Dangerous part.

In particular the higher duty of 'practicable' rather than 'reasonably practicable. If extra guarding is practicable on one machine, then I would suggest it is also 'practicable' on another similar machine.

You could research/read up on the particular EN standards that both machines are claimed to meet, with respect to guarding. There maybe a valid reason why the machines are different.

There maybe a specific Type C standard to do with CNC routers. if not a Type B for the class/type of machine.

Roundtuit  
#3 Posted : 12 October 2016 21:10:05(UTC)
Rank: Super forum user
Roundtuit

Who supplied your client - the US manufacturer or the UK agent?

The "supplier" to market is legally responsible for the CE declaration and compliance of the equipment.

Follow the invoice - if it is the UK agent politely remind them they have significant laibilities for their commission.

It is unlikely a US manufacturer would go beyond consideration of their "kit" so as you describe when full consideration of risk is applied additional safeguards are fitted.

Roundtuit  
#4 Posted : 12 October 2016 21:10:05(UTC)
Rank: Super forum user
Roundtuit

Who supplied your client - the US manufacturer or the UK agent?

The "supplier" to market is legally responsible for the CE declaration and compliance of the equipment.

Follow the invoice - if it is the UK agent politely remind them they have significant laibilities for their commission.

It is unlikely a US manufacturer would go beyond consideration of their "kit" so as you describe when full consideration of risk is applied additional safeguards are fitted.

Ryan Daines  
#5 Posted : 13 October 2016 09:36:35(UTC)
Rank: New forum user
Ryan Daines

I agree with the comments made so far, and having experienced something similar I followed PUWER Reg 11 and implemented bespoke guarding for the imported equipment.

If its paid for, on site and in use already then assess and then implement the measures using Reg 11 to guide you.

That's my view but I am interested in other thoughts. 

paul.skyrme  
#6 Posted : 13 October 2016 20:06:45(UTC)
Rank: Super forum user
paul.skyrme

PUWER is the route you need to take as the end user, however, there is no reason that this should have got this far, it should have been picked up by the procurement and the supplier it seems has supplied illegal machinery.

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