Posted By Nicholas Morris We are shortly carrying out some work which involves the purchase of a new item of machinery (not an off-the-shelf standard item, nor is it something that would operate as machinery by itself) which is to be incorporated into existing machinery to create a new assembly.. This has raised the question of CE marking, Declarations of Conformity/ Incorporation etc. We will be using the assembly within our own factory, and have no intention of selling it in the foreseeable future. I have looked into the statutory requirements and guidance and believe the approach to be adopted is as follows, but would welcome any comments/ views please. "As indicated in our earlier meeting, my opinion on what needs to be done with the assembly regarding CE marking and Certificates of Conformity differs from the recommendation of [XXX]. Currently statutory duties are dually (but separately) laid on both manufacturers of machinery for use at work and employers and users of such machinery and equipment, prior compliance, on the part of manufacturers leading to compliance on the part of employers/ users. The EU Machinery Directive (implemented in the UK under the Supply of Machinery (Safety) Regulations 1992) is a so-called "Product Directive", aimed at machinery designers and suppliers to ensure fair competition by eliminating barriers to trade. This legislation requires CE marking and Certificates of Conformity/ Incorporation. Duties of employers are incorporated into the Provision and Use of Work Equipment Regulations 1998. The primary objective is to ensure that work equipment should not result in health and safety risks, regardless of its age, condition or origin. Specifically Regulation 10 requires employers to ensure that work equipment complies with applicable Essential health and Safety Requirements (EHSRs) at the time of first supply or when first put into service. The Regulation also covers the situation where a piece of work equipment is supplied in compliance with relevant supply legislation , but the employer then alters the equipment such that it no longer complies. In this case Regs 11-19 and 22-29 of PUWER can be used to ensure that the employer returns the equipment to a state of safety and compliance (NOT the Supply Regs). Briefly these deal with the hardware aspects of PUWER'98, covering the guarding of dangerous parts of work equipment, the provision of appropriate stop and emergency stop controls, stability, lighting and suitable warning devices. Demonstration of compliance with applicable Standards is required (through the compilation of a technical file), CE marking/ CoCs not. In summary, in my opinion we require CoI from the supplier for the [yyy], we need to demonstrate compliance with applicable Standards for the [zzzzz] assembly, we do not need to CE mark or provide CoC for this."

Posted By TBC You might want to do a forum search on CE over the past year. Lots of discussion points.

Posted By David O'Hara TBC Is it possible you could send me the self cert forms. Thanks very much. David