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Mersey  
#1 Posted : 27 February 2020 07:42:34(UTC)
Rank: Forum user
Mersey

At one of the facilities I visit use a checklist to complete a PUWER assessment,I was asked a question about the checklist and I had to say " I'll get back to you on that"

What on earth does section 21 actually mean ? A real example to relate to

Conformity with EC regulations (regulation 10)

21  The effect of the wording of regulation 10(2) is to disapply regulations 11-19 and 22-29 where essential health and safety requirements of EC Directives are applied at the time of supply. In most cases proceedings cannot be taken under the hardware requirements of PUWER, unless the equipment was supplied before the corresponding requirements of the supply legislation, for example ‘The Supply of Machinery Regulations 1992’, applied.

Another aspect of PUWER that confuses me is that I can fully appreciate a PUWER assessment on a standalone equipment such as pallet wrapper or a baler as its obvious where it starts and finishes, but how does PUWER apply to a manufacturing process with lots of kit connected together? Where does it start and stop? I'm thinking a process with several pumps connecting pipework vessels heat exchangers spray dryers HMI panels etc. Does it apply to these situations and working equipment is a broad term ? Or is it sufficient to rely on the commissioning  documentation and its supporting evidence as the basis of safety for using the kit? I suppose the only interaction the employee has is with the HMI panels

Ian Bell2  
#2 Posted : 27 February 2020 12:15:10(UTC)
Rank: Super forum user
Ian Bell2

Given the current Brexit situation this topic is likely to change.

Reg 10 is about 'CE' marking of new machinery made and supplied via the EU Machinery Directive i.e. requiring manufacture to comply with the Essential Health and Safety Requirements of the Machinery Directive

If not CE marked machinery cannot be legally supplied within the EU. Therefore cannot be PUWER compliant if not CE marked.

For sub components a Declaration of Incorporation is issued - indicating what standards have been used to shoe compliance with the EU Directive

For completed machinery a Declaration of Conformity is issued.

Remember these are 'the easiest trade negotiations eve'. Our glorious leaders are going to make one heck of a mess of things.

thanks 2 users thanked Ian Bell2 for this useful post.
CptBeaky on 27/02/2020(UTC), jmaclaughlin on 10/03/2020(UTC)
Mersey  
#3 Posted : 27 February 2020 12:36:57(UTC)
Rank: Forum user
Mersey

Thanks for the reply Ian

I understant the first bit of your reply

If not CE marked machinery cannot be legally supplied within the EU. Therefore cannot be PUWER compliant if not CE marked.

But don't understand the rest where can i read up on it? I've been part of teams buying and assessing equipment completing FAT's SAT's design stage risk assessment, hazops, FMEA etc.. Are these the types of behind the scene documentation that add up to a declaration of conformity and therefore not required to be PUWER assessed ?

What do you mean by sub components ?

Many thanks

Ian Bell2  
#4 Posted : 27 February 2020 14:26:13(UTC)
Rank: Super forum user
Ian Bell2

The EU machinery Directive is enacted in UK law via the Supply of machinery (Safety) Regulations

Further information for the following

Declaration of Incorporation

https://www.hse.gov.uk/work-equipment-machinery/declaration-incorporation.htm

Declaration of Conformity

https://www.hse.gov.uk/work-equipment-machinery/declaration-conformity.htm

Ron Hunter  
#5 Posted : 27 February 2020 17:11:45(UTC)
Rank: Super forum user
Ron Hunter

Your reference is to Regulation 10 of the 1998 version of PUWER. Reg10 was amended by SI 2002/2174.

Yes, 2002.

See latest free L22 download.

Ian Bell2  
#6 Posted : 27 February 2020 20:43:20(UTC)
Rank: Super forum user
Ian Bell2

Makes it slightly easier to understand - at least Sched 1 referenced in Reg 10, lists the relevant EU Directives.

It was always confusing in the early days of PUWER what Reg 10 did actually mean.

The general principle applies - in the EU, work equipment has to be CE marked to be legal if not otherwise excluded.

paul.skyrme  
#7 Posted : 09 March 2020 18:41:09(UTC)
Rank: Super forum user
paul.skyrme

Mersy,

Can you please clarify, when you say section 21, you are referring to what please?

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