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#1 Posted : 09 December 2004 21:27:00(UTC)
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Posted By Lynsey Jones I am currently studying for my MSc in Occ. H&S Management with Loughborough University. My research subject is looking at the misconception of the end user regarding what CE Marking means - their perception that it is a guarantee of safety when it is not. Could anyone direct me to revelant articles discussing the confusion that CE Marking caused on its introduction or since its introduction? I am also looking at PUWER and have been advised by an HSE Inspector that Regulation 10 has been amended and the amendments have been published separately. Has anybody reviewed this amendment or do they have the correct details of it to enable me to obtain it. (Unfortunately the HSE Inspector was unable to do so!!) In addition to this.... I am also trying to make contact with the UK Surveillance Group that monitors Products with CE Marking entering the UK for compliance. The DTI have yet to respond. Can anyone guide as to who might be a good contact. If you can help in any of these areas please get in touch, it would be greatly appreciated Many thanks Lynsey Jones
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#2 Posted : 10 December 2004 10:39:00(UTC)
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Posted By Jim Walker Lynsey, Contact the (Loughborough)University H&S office. The recently retired Safety officer is/was doing a very similar PhD thesis. I don't want to put his name here, but I'm sure the H&S office secretary will help you contact him.
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#3 Posted : 10 December 2004 11:34:00(UTC)
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Posted By J Knight The changes your H&S person referred to are in the Health & Safety Miscellaneous Amendment Regulations 2002, John
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#4 Posted : 10 December 2004 20:22:00(UTC)
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Posted By Stuart Nagle As we all know (don't we)? CE marking distinguishes the equipment in question as meeting and complying with all the relevant standards that are applicable to the equipment. The question to be asked is, if some of those standards are in fact safety standards, could Lindsay's assumption in the original thread above 'My research subject is looking at the misconception of the end user regarding what CE Marking means - their perception that it is a guarantee of safety when it is not', be correct. If there is a misconception, could it be that the relevant standards applicable are not known or fully understood, and therefore it is assumed, without relevant knowledge that the equipment is safe in operation regardless of where or how it is used or integrated into a (production) process. This I think is a considerably different, but more applicable question in respect of CE Marking... After all, if you are unaware of the relevant safety standards applied, how can you be sure that, in operation, the standards are being met or complied with. Taking this a stage further and relating it to a 'safety device' e.g. an opto-electric safety guard, the potential for misunderstanding, particularly when other non CE applicable standards relate to installation, become apparent. Stuart
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#5 Posted : 11 December 2004 12:20:00(UTC)
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Posted By D. Hilton Lynsey At the risk of annoying some in the forum "I have contacted you direct" and as you now know the legislation in question is SI 2002 No. 2174 Health & Safety (Miscellaneous Amendments). Stuart, CE Marking where provided does not necessarily distinguish equipment as meeting and complying with all the relevant standards that are applicable but in fact the marking gives a visual indication that the equipment complies with the essential health & safety requirements specified within an applicable new approach directive e.g. Machinery, Low Voltage, EMC, PED, ATEX etc, it is not mandatory that a harmonised standard be used to demonstrate that an EHSR has been complied with. In relation to the use or knowledge of applicable standards, where any harmonised standard has been used to provide a presumption of conformity in relation to an EHSR, the reference to the EHSR used is specified within the Declaration of Conformity or Manufacturers Declaration which should accompany the equipment. With regard to the opto-electric safety guard, this is defined as a safety component and as such must not be provided with a CE mark but as Annex IV equipment it must be subjected to a type examination by a Notified Body and an EC Type Certificate and Declaration of Conformity must be provided. At the end of the day, compliance with any new approach directive was intended to provide for free movement of goods throughout the European Union it was not intended to be a guarantee of safety. However, taking into account that conformity is based on the compliance with minimum essential health & safety requirements and that routes to conformity e.g. use of harmonised standards or other means are subject to risk assessment, it is understandable that an individual could assume that end users perceive CE marking as a guarantee of safety. From the research that I have carried out I do not believe that is the common perception. E.g. only 9.7 % of respondents in a study of 16.082 respondents within the European Union held the opinion that a CE mark indicated that a product was safe, the majority 34.1% expressed the view incorrectly that the marking indicated that the product was manufactured within the EU. Regards Darren
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#6 Posted : 11 December 2004 17:31:00(UTC)
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Posted By Struan Does that then mean that if an electro mechanical "machine" has a CE stamp originating from the original "European" manufacturers, that all components fitted to it are as CE as well, to fully comply with the "end of use" safety requirements? As I understand, the CE mark means that the individual commodity has been "safety" tested to meet the requirements of end use as it was indended for, be it children, adults, animals or proccesses, factories etc. This could be an opto-electronic safety device or a childs cuddly toy.
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#7 Posted : 11 December 2004 18:50:00(UTC)
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Posted By Laurie I repeat my response(s) to earlier threads on this subject - self adhesive CE stickers can be purchased from most industrial and signage catalogues, and are included in most signage software packages for printing on any computer. All they prove is that the supplier is trying to sell into the European market! Laurie
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#8 Posted : 12 December 2004 18:41:00(UTC)
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Posted By Stuart Nagle People. When I looked into CE marking previously, in depth, I looked at the standards that applied to CE marking specifically - referencing and reading the information avaialble from the CE European Standards and the application to plant/equipment ect. The standard states catagorically that CE marking applied to equipment implies that all relevant standards (not necessarilly safety standards) - but those relevant to the machine type and its construction/components ect, employed in the manufacture meet all the relevant standards applicable to its construction. In respect of my example of an opto-electric safety device, I was trying to show that redgardless of the fact that CE marking may be shown on equipment, there may in fact be additional standards that have to be complied with to ensure that the safety device was installed correctly, taking into account speed of approach of persons, distance from device for which protection was sought, shut off time of the safety device and equipment it is protecting (in microseconds) positioning of the opto sensors and a whole lot of other stuff, not covered by any CE marking on the safety device itself. This I think exemplifies that although CE marked, it shows that it does not follow that the equipment can be assumed to be safe, unless properly installed in accordance with any other relevant standards applicable, regardless of its type or the nature of installation. Hope this clarifies my comments above... Regards... Stuart
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