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Posted By Paul Elliott
Our waste minimalisation department have taken delivery of several 'Kan Krushers'. Basically these are a device that is fixed to a wall to crush cans by placing a can between two plates and pulling a lever downward.
I would like to know where we stand with regard to CE marking. The manufacturer states that there is no category that they could fall into and that the HSE were involved in an advisory capacity at the design stage. Is there anyone who may be able to advise me on this topic?
Thanks
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Posted By Jane Blunt
Dear Paul
It is possible from your description that CE marking is not required.
It is required for the following:
Most electrical equipment,
Machinery,
Toys,
Simple Pressure Vessels,
Pressure Equipment,
Equipment for Use in potentially explosive atmospheres,
PPE,
Telecommunications equipment,
Explosives for civil use,
Active implantable medical devices,
Medical Devices,
Gas Appliances,
and one or two others, I am sure.
Your description implies no electrical supply. Is it a machine? There is at least one part that moves, but if it is powered only by manual effort it is exempt (an exception is equipment for lifting and lowering loads). Pressure equipment regulations do not apply if there is no working fluid under pressure.
Why not browse the DTI website?
http://www.dti.gov.uk/strd/strdpubs.htm
Regards
Jane
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Posted By Jim Walker
I would say your can crusher is a machine (Supply of Machinery (safety) Regulations 1992 definition: “an assembly of linked parts or components, at least one of which moves”). Your can crusher is exempt from the requirements of the Machinery Directive because there is an specific exemption for “machinery whose only power source is directly applied manual effort”.
However, in my opinion, PUWER applies i.e. you need to assess the risks.
I’ve commented elsewhere on this forum that relying on “CE marks” to ensure safe equipment is unsafe practice. This is a widely held view I have received from people far more expert, than I profess to be.
I think it is highly unlikely that HSE would be involved in or comment on equipment design, I suggest you ask the manufacturer for details of this collaboration. This may well bring in howls of protest, but I suspect the HSE have very few staff capable of advising, anyway. Any manufacturer who does not give your valid request a sensible reply has got to be suspect.
If you plan to do a risk assessment, have a look at PD 5304:2000 published by BSI.
I suggest you ask yourself if it is possible to get a finger tip (or worst) trapped/crushed etc in the machine.
The argument on the manual effort required, suggests as soon as you start to crush the trapped digit, you would stop applying force and thus avoid serious injury. Does the machine allow release at this point? Some might have a one-way ratchet. Might one person be feeding (cans) and another applying the force – even if it is designed for one person operation. Usual gap size to restrict access of fingers to moving parts is 6mm, but what about children – technical advice (more detail) on this can be found in BS EN 294:1992.
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Posted By Andrew Rushton
Please do not rely on on CE marking. I work for a large food manufacturer and have had cause to prohibit the use of new CE marked equipment for basic guarding issues.
Rely on your risk assessment.
With regard to can crushing equipment, watch out for trap hazards in the lever mechanisms.
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Posted By Laurie
CE Labels cost £27.60 per 250, and can also be produced on any computer.
From a safety standpoint they are not worth the glue they are stuck on with
Laurie
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Posted By Jane Blunt
Dear All
While I would agree that most CE declarations are worthless, this is not because the principle of CE marking is bad.
It is because most declarations that are made are done through self assessment, without understanding the requirements, and are basically false. i.e. the declaration says the equipment is safe, when in fact it is not.
The solution to this problem is not to scrap the CE system, but to enforce it's principles, perhaps via s6 of HSAWA.
This problem is not unique to CE marking - the quickest way to get a black belt in a martial art is to buy one in a shop. You can wear the belt with impunity, but it does not make you any good at the art.
Jane
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