If you're confident the machine is 15 years old and supplied to you at that time, have you asked the OEM for a copy of the certificate of conformity? Do you have a handbook, warranty etc - which should be referring to that CoC?

Hi Mersey,

All the advice given here is correct, in terms of how to deal with this in the real world I would agree with Ian Bell2 on this one. The offence is always 'unsafe' machinery, and that is what we want to avoid. As the machine has been operational for 11 years the supply phase ship sailed long ago, in that sense conducting a risk assessment against the requirements of PUWER is the right thing to do here. If not already, I'd want to be sure whomever is carrying out the risk assessment is competent in terms of machinery risk assessment. A subject often over complicated by many, but in the same breath not something want to get wrong given the risks involved with certain bit's of kit. So don't condemn, risk assess it against the requirements of PUWER and make sure it's safe.

Quote from Bigmac1

Not on my watch, if I thought I might get an improvement notice then id do something about it.These pallet wrappers have been responsible for numerous fatalities so id be pulling out the stops cos " at woerse you could be spensing time at her majesties service"

Quite the harbinger of doom. Perhaps Bigmac can outline how the poster - with a diligent application of PUWER and presumably recording of the findings from their review of the Essential health and safety requirements relating to the design and construction of machinery as cited above - could end up in prison?

Yes there is a risk with using the equipment - recognised by the poster, and that risk sounds to be generally percieved to be managed OK up to now, Now he wants to be thorough, by going back to basics to cover all that the CE marking woulda / shoulda established. Don't forget, CE marking is self-certification by the manufacturer, and so not an exact science anyway. No reason why the company can't make the decisions for itself in the absence of the label. Which is 'pulling out the stops' by another name.

Without contradicting - a CE mark takes priority over a BS mark/number.

For machinery under the Machinery Directive (or any other relevant EU Directive e.g. EMC Directive) a 'CE' mark is a legal requirement before the produce can be sold 'placed on the market' within an EU country.

All a BS or EN number shows is that a particular machine was designed to a particular standard (which helps to satisfy the Essential Health and Safety Requirements which must be satisfied under the Machinery Directive so a CE mark can be applied to the product.)

There may be alternative standards that could equally have been complied with to give the same end result to allow the product to be CE marked.

The web link provided above shows a phone number. Proper thing to do is call them and pursue that Certificate of Conformity, or confirm it predates those requirements.