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Posted By GDP
In regards to CE marking, under the 98 machinery directive and in relation to installing a new production line comprising of several machines, is it sufficient to install equipment that is individually CE marked, or does the entire production line need to be CE marked prior to/ following installation?
Obviously national legislation such as PUWER in the UK and the General Applications in Ireland put onus on the purchaser/ operator to risk assess the line. However I always believed that as long as each individual component was CE marked, this would be sufficient to comply with the 98 Directive ... that was until someone said to me that there may be a requirement to CE mark the entire line.
Any help clarifying the above would be gratefully received!
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Posted By Pete Longworth
As far as I understand it if a piece of machinery is to be added to other machinery then it would need an individual certificate of incorporation rather than a declaration of conformity.
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Posted By Mitch
I agree with Peter, my understanding, and our practise is that unless you join together machinery and it 'significantly alters or changes the operation' of the original machinery you do not CE mark.
Mitch
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Posted By Pete48
My understanding of the difference between CE marking (a Declaration of Conformity) and a Declaration of Incorporation is that:
If a machine is sold with a CE mark, this certifies that it meets all ESHR etc. (sort of safe to go with the usual caveats)
If it is designed to be incorporated or assembled into a bigger machine and therefore not ready to be used safely, it will be given a Declaration of Incorporation. To quote the HSE guidance "In practice, this means that the machinery should not be used until the final product has been manufactured, all relevant essential health and safety requirements met, and a declaration of conformity issued - by the final installer or assembler." The Declaration of Conformity (CE mark) then applies to the total assembly or incorporation once fully complete.
as you say, there is a clear duty to assess the final assembly, however complex or large. To be suitable and sufficient I would argue that it will have to cover all the technical areas similar to the Declaration of Conformity and it is thus sensible to follow the same protocols and use the same standards for doing same. Completing this type of assessment will rely upon the CE marking or Incorporation Certs of individual machines but will have to consider whether the machines are safely linked and, in doing so, that no new hazards are created. Once complete, you can issue a CE mark for the line.
I must advise, however, that these comments are based on personal experience of doing what works best rather than any statement about the actual definitive legal position as to whether you mark or not. I think you must but....
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Posted By Mr Adrian D Everett
Interesting topic this one and one that many are confused about. But my understanding relates to the emergency control system of the machinery, if they are linked then you have to CE mark as a whole machine, else they are stand alone.
Nonetheless, when purchasing machinery the supplier builds it to do a job, but you want it to do a job in your environment, so once installed, the CE marking provides a level of documentation to enable you to ensure you fully comply with PUWER Essential Health & Safety Requirements, but you have to check that it is safe to operate within your environment; and that maybe that the machine is linked with others, in a dust/wet atmosphere, poor lighting, local to FLT gangway, run by pregnant ladies, etc. Your local issues need to be assessed, and recorded too. PUWER is the higher conformity level than CE marking.
So you should not operate any machinery until the whole assembly/area has been PUWER assessed in the above manner, and once the necessary measures are in place then it is OK to press the GREEN BUTTON!
Lastly, if you are getting a Declaration of Incorporation from the supplier, ensure you understand what the residual risks are, get the supplier to list them for you (they should know what they would have done to CE mark it!), you can then ensure that you can review and cover them off when installing them into your facility. You will have to do the CE marking of such a machine/assembly, so you need to know what you have to attend to (from a machine point of view only that is). PUWER assessment then follows!
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Posted By kaggs You will need to CE mark the whole line even if you have individually CE marked machines etc. If you need any help then please contact us at: john.glover@gloverassociates.co.uk
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Posted By GDP
As a newbie to this forum, I just want to thank everyone for their advice so far. Very much appreciated. Hope I can return the favour some time.
In regards to the topic, it still seems quite a murky issue - especially as in the past I would have taken the pragmatic view that if the individual machines and link conveyors/ control systems are CE marked and there are no changes to the safety design of the equipment (for example, linking the e-stop circuits of the machine - therefore changing the operation of the respective safety relays/ plc's), the complete line would not need to be CE marked. In this regard my views would have traditionally tied into Adrian's view ... that was until reading the other posters' views!
As with all health and safety information, it seems the answer is never 100% black or white ...
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