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We are bringing in some equipment from a sister site inEurope. The equipment predates CE marking. What obligations do we have?
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Rank: Super forum user
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Rank: New forum user
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Thanks Ron, Perhaps what I doidn't make clear was that there is no change of ownership/sale - the equipment is staying within our European group.
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Rank: Forum user
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Michelle,
You need to ensure that they are safe to use. If they meet the Essential Health and Safety Requirements of the Supply of Machinery regs, then you should be OK, although it will mean an assessment of each machine (prior to being used in production). Then you may have to add further controls ie interlocks, "E" stops, guarding etc or modify existing.
The CE mark (which you don't have) doesn't necesarily mean the equipment is safe to use, it just indicates that it was built to a minimum standard, so the overriding issue is to ensure any equipment is safe to use.
Holmezy
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Rank: Super forum user
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Michellew,
If you refer to Ron’s 2nd link about 1/3rd way down page, point 8, you’ll see the HSE recommendation for this.
There is not a requirement to CE mark any machinery unless substantially refurbished if it pre-dates the requirement see point 9
If you had to CE mark every piece of use machinery sold in the UK/EU then it would kill the used equipment market overnight!
HSE refer to HASAWA Sect 6, however, other regs will also apply under HASAWA, PUWER98 etc.
HTH.
Paul
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Rank: New forum user
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Thanks for your input - that was the conclusion I'd reached in my own mind but I really appreciate greater knowledge than mine putting a comment to the question.
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Rank: Super forum user
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By "Europe" do you mean another EU Member State?
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Rank: Forum user
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Hi Michelle et al,
Hmmmm, what regular inspection if any has this equipment undergone in it's lifetime? Is it recorded? and can you access these records (if any exist).
What was the original country of manufacture and what year? even though It may pre date The EU Machinery Directive/SMR Regs I would, to be prudent, ensure that someone looks at the equipment from a PUWER 98 or similar current legislative view as it will need to be inspected under puwer 98 or similar from installation date 2010. The manufacture standard used in construction should be referenced when inspecting - but so should the modern requirement for interlock, blast zones, lighting, guards etc. etc.
I'm not sure that the age of the equipment would be considered if there was an incident where a guard, or interlock could have been retro-fitted to prevent injury, discharge, failure etc. etc.
Yours aye
db
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Rank: New forum user
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The equipment is coming from within the EU but at present, I don't have the detail you suggested necessary (country of origin, date of manufacture etc) We plan to put it through a thorough PUWER assessment and it will fit into our routine pm scheme of inspection, ppre-use checks etc. We'll try to get it's history, donor site assessments etc biut bring it up to the standards required for UK use.
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