Rank: Guest 
|
Posted By Joanne Laing
Can anyone point me in the right direction as to whether a blow moulding machine refurbished in house - would need to be CE marked again?
Would it be enough to just ensure that any refurbishments carried out were in line with the PUWER 98 regs??
I'd appreciate any help.
Ta Jo
|
|
|
|
|
|
Rank: Guest
|
Posted By Mike Draper Jo You should probably have a look at www.dti.gov.uk/strd/strdpubs.html and look at the guide for machinery. This should steer you in the right direction. But as a starting point the question you have to ask yourself is whether or not the refurbishment of the machine has resulted in a change of use of the equipment. That is, have any changes been made to the way the machine works, the speed at which it works, the duty of the machine, the controls, the guards etc. that means that it is no longer the same machine? If the refurbishment is basically cleaning and replacement of worn out parts with identical parts so that the machine is functionally the same, then the machine should not require CE marking. As a note, it doesn't matter whether a company makes it own machinery or buys it, all new machinery must be CE marked by the manufacturer or the importer (where manufactured outside of the EC). By doing so, this practically discharges the duties of the user under Reg 11 of PUWER, providing the equipment is installed and used in accordance with the instructions and limits of use. Mike
|
|
|
|
|
|
Rank: Guest
|
Posted By TBC Even if you build from scratch for internal company used you don't need to CE mark it. It is only if you intend to sell the machines you build that the CE comes into force. As long as you comply with the relevant regs for Electricity and PUWER etc you will be OK. Record all the actions and engineers reports etc. and retain them on file with signatures. See the attached link: www.ce-marking.org/what-is-ce-marking.html
|
|
|
|
|
|
Rank: Guest
|
Posted By Mike Draper TBC While the site you refer to may well give that particular interpretation, I normally refer to the EC's own web site and their discussion on and interpretation of the Machinery Directive, as I suspect they might be considered slightly more authoritative. They make it quite clear that irrespective of whether a machine is intended for own use or sale, if ultimately it is intended for use within the EEA then the Machinery Directive applies. As I understand it, it is all down to the wording of articles 2 and 8. Therefore, if you build your own machines, then you have to CE mark them - no exceptions. There doesn't have to be a commercial transaction. The Machinery Directive does not apply only where you are carrying out maintenance work to keep existing machinery in a serviceable and safe condition, as required by UWED (PUWER). You can find the relevant documents at: http://europa.eu.int/com...ment/machinery/index.htmMike
|
|
|
|
|
|
Rank: Guest
|
Posted By Ron Hunter
My opinion Joanne (ex-Trading Standards) is that CE marking not required -your assertions are correct. Try your local Trading Standards for advice on this.
|
|
|
|
|
|
Rank: Guest
|
Posted By TBC
Don't see that Mike - as I read it, it talks about the manufacturer as a body producing for sale nothing about own build for internal use.
Sorry!
|
|
|
|
|
|
Rank: Guest
|
Posted By Adrian Watson
The relevent regulations in the UK are the supply of machinery (safety) regulations 1992 (as amended). Whilst these regulations only apply only to relevent machinery supplied in the course of a business, Regulation 11 states:
11.—(1) Subject to paragraph (3) below, no person shall supply relevant machinery unless the requirements of regulation 12 below are complied with in relation thereto.
(2) Where a person—
(a) being the manufacturer of relevant machinery, himself puts that relevant machinery into service in the course of a business; or
(b) having imported relevant machinery from a country or territory outside the Community, himself puts that relevant machinery into service in the course of a business,
for the purposes of these Regulations that person shall be deemed to have supplied that relevant machinery to himself.
(3) The requirements of paragraph (1) above do not apply in relation to supply by any person of relevant machinery which has previously been put into service in the Community.
So relevent machinery built by yourself does have to conform.
Regards Adrian Watson
|
|
|
|
|
|
Rank: Guest
|
Posted By TBC
Ah yes - It has to conform to the relevant regs, but doesn't really require 'CE' marking. If it does conform to all the regs you might as well CE mark it anyway, because that is all part of the self-certification process.
|
|
|
|
|
|
Rank: Guest
|
Posted By Adrian Watson
Reg 12.—(1) of the supply of machinery (safety) regulations 1992 states:
The requirements of this regulation are that—
(a) the relevant machinery satisfies the relevant essential health and safety requirements;
(b) the appropriate conformity assessment procedure in respect of the relevant machinery has been carried out by the responsible person in accordance with one of the procedures described in regulations 13, 14 and 15 below;
(c) the responsible person, at his election, has issued either—
(i) an EC declaration of conformity in accordance with regulation 22 below; or
(ii) in the case of relevant machinery to which regulation 23 below applies, a declaration of incorporation in accordance with that regulation,
in respect of the relevant machinery;
(d) except in the case of relevant machinery to which regulation 23 below applies, the EC mark has been properly affixed by the responsible person to the relevant machinery in accordance with regulation 25 below; and
(e) the relevant machinery is in fact safe.
Please note the affect of Reg 12(1)(d) - all relevent machines (expect part machines - Reg 23 refers) must be CE Marked in accrodance with Reg 25.
Regards Adrian Watson
|
|
|
|
|
|
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.