Rank: New forum user 
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If you begin a Puwer Risk Assessment programme on a site that does not currently have them, how would you apply regulation 10, (Conformity with Community Requirements). The work equipment is older than the PUWER Regs and was originally installed before the Regs came into force. The equipment installed after PUWER came into force was second hand and not new. Does the CE markings and certificate of conformity apply to equipment installed after PUWER came into effect which was made prior to PUWER/
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Rank: Super forum user 
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Reg10 is not exhaustively retrospective. Have a read of the L22 ACoP (free download at HSE) for extent of retrospective application, e.g. para 200:
'........ nor are product Directives retrospective. However, equipment which was provided for use in the European Economic Area before compliance with the relevant product Directives was required, may need to be modified to comply immediately with regulations 11–24 of PUWER 98.'
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