Rank: New forum user 
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My company based in Germany has designed and manufactured a specialists drilling rig for operation in UK territorial waters from a foreign register ship. The equipment is issued with the EC Declaration of Conformity (DoC) and place CE marking on a product. The equipment will be operated by our own employees. I have been informed that this equipment cannot be used without first being PUWER risk assessed is this correct.I have checked all sorts of publications and contacted the HSE for clarification. IOSH have expressed the feeling that the CE process would suffice on this case, but I am looking for a definitive answer to this question.
can anyone shed some light on this subject
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Rank: Super forum user
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There is no strict requirement under PUWER to undertake a risk assessment.
Risk assessment of machinery/work equipment is justified as the Management of health and safety at work regs have a general requirement for 'risk assessment' where/of significant hazards might exist.
Probably a key issue here is the fact the machine is going to be used by your own employees.
Often the issue with CE machinery / new machinery is how it integrates into an existing factory/facility - training of new users, how/where a new machine will be installed etc.
I would tend to agree that in this case, there is little additional practical benefit in completing an additional 'PUWER risk assessment', as you should have covered the key issues already with your design process and training of your own staff.
I guess some zealous auditor might complain about a lack of a PUWER risk assessment.
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 1 user thanked Ian Bell2 for this useful post.
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Rank: Super forum user 
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Strictly you should assess it under PUWER, if you don't how will you know that as the end user it is correctly implemented and safe to use by your users. A PUWER assessment is not really a risk assessment. You also need to verify under PUWER as the end user that the CE marking is correct and legitimate really. The risk is down to your employer, however, the unit has a DoC, how has it been integrated into the vessel, has this changed the risks and hazards? If you don't assess it, how will you know. Mind, I my first reaction was that these requirements may not apply to ocean going vessels, I would have to check, I may well be wrong, it's late, and I've had a bad day.
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1 user thanked paul.skyrme for this useful post.
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