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In-house made machinery requirements: CE mark, PUWER or both? - Machinery
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gazbut  
#1 Posted : 06 November 2016 09:00:40(UTC)
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gazbut
Hi all.
As a manufacturing company we have a tool room that occasionally manufacture dedicated machines for use in our assembly areas.

My question is what assessments do these machines need when they are not going on the open market, they are for in house use only?

For example - a fully automated drilling and cutting machine has recently been made. This machine takes a component, cuts it to length and drill required holes. It only does one size of component, it is fully enclosed, has interlocks on all access doors and has perspex windows. The only aperture is where the component is fed into the machine, guarding at this aperture makes it impossible to reach any moving parts.

All sourced components used in its construction were individually CE marked but the whole machine is not.

I have done a PUWER assessment and was involved from the very start of its design.

I would really appreciate your thoughts on this?

Regards

Gazbut
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paul.skyrme  
#2 Posted : 06 November 2016 09:09:30(UTC)
Rank: Super forum user
paul.skyrme
The machinery directive, etc. specifically includes the requirement for the CE marking of machinery made by a company for their own use.
Thus the answer to your question is that it does require CE marking.
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thanks 1 user thanked paul.skyrme for this useful post.
gazbut on 06/11/2016(UTC)
Ian Bell2  
#3 Posted : 07 November 2016 08:28:52(UTC)
Rank: Super forum user
Ian Bell2

Agree with Paul. Even if a machine is just for own use, it is still being 'placed on the market' as defined under the Machinery Directive. Full CE marking and DoC/Technical File required, demonstration of compliance with the MD Essential Health and Safety Requirements etc.

Also any other relevant EU Directives, if applicable e.g Low Voltage Directive, EMC Directive, ATEX Directive.

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Ellwood  
#4 Posted : 09 November 2016 15:07:53(UTC)
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Ellwood

At the risk of sounding like Ernest Moss you quote the use of Perspex which is a trade name for Acrylic. Are you really using acrylic for guards or is it a generalisation like calling all metal iron?

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jay  
#5 Posted : 09 November 2016 17:59:02(UTC)
Rank: Super forum user
jay

You may find this useful:-

Machinery manufacturers: legal responsibilities (The 'responsible person' for the machinery or assemblies produced, compliance with health and safety regulations, and duties to demonstrate compliance.)

https://www.gov.uk/guidance/machinery-manufacturers-and-their-responsibilities

MACHINERY-Guidancenotes on the UK Regulations  SEPTEMBER 2009

http://webarchive.nationalarchives.gov.uk/20090609003228/http://www.berr.gov.uk/files/file52968.pdf

Guide to application of the Machinery Directive 2006/42/EC - Europa

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paul.skyrme  
#6 Posted : 09 November 2016 19:21:31(UTC)
Rank: Super forum user
paul.skyrme
Originally Posted by: Ellwood Go to Quoted Post

At the risk of sounding like Ernest Moss you quote the use of Perspex which is a trade name for Acrylic. Are you really using acrylic for guards or is it a generalisation like calling all metal iron?


There is nothing wrong with using PMMA, or Polycarbonate (Perespex/Makrolon/Acrylic) for machinery guarding vision panels providing the impact energy calculations have been correctly undertaken and the panel has adequate strength.

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gazbut  
#7 Posted : 09 November 2016 21:21:44(UTC)
Rank: Forum user
gazbut

Hi,

Thanks for the information.

The quoted Perspex name was just a generalised term, to be clear it is ballistic grade polycarbonate.

Now it is clear that the CE marking is a requirement we will be bringing in a consultant to produce a technical file and certification.

Cheers

Gazbut
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