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Posted By steven n
My company manufactures equipment solely for our own use and therefore we have never needed to CE mark our equipment. It has now been requested by our client that we CE mark our kit, we have the declaration of conformity and safety file etc. Can we go ahead and CE mark?
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Posted By Guderian2
You do need to CE mark, even if only used internally, your company is still 'supplying' a machine? 192 Supply of Machinery Regs apply. Assuming you are in the UK/EU
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Posted By Flic The DTI is a mine of information about CE marking. A good place to start is the list of Directives which is here: http://www.berr.gov.uk/w...ions/ecdirect/index.htmlFor many products it is perfectly legal to self certify that they attain the required standards, but for some it is necessary to enlist the services of a Notified Body, to give an independent check of the item's safety. Flic
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Posted By steven n
Guderian,
As far as I am aware,CE marking only needs to be done when placing equipment on the market which we do not nor intend to do.
Steve
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Posted By Guderian2
But you are placing the equipment/machinery 'on the market' even if it is only being used within your own company and no money is changing hands.
Your equipment will still have to satisfy the EHSRs (Essential Health & Safety Requirements) for the caregory of machine/equipment you are supplying.
However, both within the Supply of Machinery Regs and also The Pressure Equipment Directive (if this is applicable) there are a number of exclusions relating to intended use, groups of equipment and the route to which you much demonstrate compliance before your can issue you your declaration of conformity and then CE mark it.
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Posted By Flic
It was always my understanding that equipment fabricated exclusively for one's own use did not have to be CE marked, as well. Of course, it still has to satisfy the essential safety requirements.
This belief is based on a statement in the DTI guidance booklet 'Electrical Equipment (implementing the Low Voltage Directive)', July 1995, document URN 00/588.
There is a heading within the document covering electrical equipment intended for use by the manufacturer within his own premises, and this specifically states that it does not require CE marking.
I cannot find an equivalent statement in the Machinery guide (URN 95/650), but it does state that the definition of 'supply', which is the trigger for all of this is that to be found in Section 46 of the Consumer Protection Act 1987.
I don't have time to follow that up, but I hope it helps
Flic
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Posted By Pete Longworth
Flic
That is certainly my understanding as well. How you could consider making a piece of machinery for internal use to be "placing on the market" I don't now. Surely that is the whole point. The machine is for internal use, not for sale or hire, therefore not on the market.
One point of this thread however seems to have been missed and that is that a client is requiring someone to CE mark a piece of equipment that is strictly for internal use. What right has a client to do that?
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Posted By steven n
Pete,
You are quite right in saying the client has no right but as you know the client usually gats what the client wants!!
The BERR and CE websites were very informative we are a lot clearer on what we need to do now thanks.
Have a good weekend all!!
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Posted By Colin
The key term is 'use'. Placing into use is interpreted to meet the term 'placing on the market'.
The client does have a right to insist that its suppliers comply with the law. To knowingly ignore a breach, or to condone or be complicit in a breach would most likely render the client liable or part liable for any accident or loss flowing from the breach.
Colin.
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Posted By Tom Doyle
I think we should keep things in perspective. The CE mark is just that; a mark.
It is my understanding that the intent of the mark is to communicate to the user of the product that said equipment meets the essential H&S requirements of the EU.
When we get into these types of discussions it is imperative to keep in mind that all of the legislation, including that which creates the requirement for the mark, is put in place with the end goal of protecting workers.
Mark or no mark the intent is still the same. Make products for use in the workplace that are manufactured such that, when properly used, they are not likely to cause injury.
If you are manufacturing products for your own use, manufacture them such that they at least meet the requirements of the applicable standards.
For machinery start with ISO 14121:2007, ISO 12100- 1,2:2003. Work you way through the details of the other relevant standards.
If you choose not to use the standards as a guide to manufacture low risk products perhaps you should buy the products from a company that does. Then you can let them apply the CE mark.
At the end of the day your workers deserve the same degree of protection regardless of whether or not the CE mark is applied.
Happy Friday from across the pond.
Tom Doyle
Industrial Safety Integration
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Posted By Colin
Totally agree with the sentiments expressed in relation to the underlying intent of product certification.
However, the law supporting the CE approval system is somewhat more complex and whilst the requirements can at times be applied quite rigidly, at other times support for the safety elements of the system is somewhat lacking. In particular:
It is an offence to place certain products on the market without CE approval and application of the mark;
The CE approval relates to product standards, the operation of the free market and to all users of such products, not just those in the workplace;
The CE approval process is not specific H&S law. It relates to freedom of trade. The European Court has followed the trade based approach in recent judgements in H&S related cases under the Machinery Directive.
Whilst the intent in relation to safety appears straightforward it is often not. Manufacturers and suppliers are well advised to consider the detailed requirements of the CE based product approval requirements.
Colin.
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Posted By Tom Doyle
Colin,
Well said. I couldn't agree more. The product conformity process can be quite complex. I didn't mean to imply that it was at all simple.
I think it would prove beneficial if people had a better understanding of their limitations, with regard to product conformity, and solicited help when they are unsure of equipment design requirements.
This was the intent in replying to the original post.
Cheers,
Tom Doyle
Industrial Safety Integration
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Posted By Guderian2 For those who doubted/gave advice regarding CE marking for machinery made and supplied on an 'internal basis self manufactured basis' - just to remove any doubt - you will probably have to CE mark in such cases. See quote below 'Having complied with these requirements the manufacturer can freely place the machine on the market anywhere within the EEA. Should a manufacturer fail to comply with these requirements there may well be a breach of the criminal law in both the country of origin and the country of supply. Placing on the market for the first time, means on the Single Market (within the EEA) after 1st January 1995, when the provisions of the Machinery Regulations (with certain exceptions) became mandatory. This would exclude from the Machinery Regulations second-hand machines already in use in Member States before 1st January 1995 but would include second-hand machines originating from outside the EEA which are placed on the Single Market after that date. The Machinery Regulations also cover machines made or assembled within the within an organisation for its own use.' Web link http://www.berr.gov.uk/w...rect/ipsg/page13049.htmlHowever, there are still a number of types of machinery and exclusions that may apply. CE marking/Supply of Machinery Regs are not the best or easiest legislation to understand I think we can all agree on that.
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