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ianjones  
#1 Posted : 12 May 2021 17:25:17(UTC)
Rank: Forum user
ianjones

my company has 20 machines of 2 types (spot welders) and a further 10 machines that they have built themselves none of which have CE marking.

I have advised them that this is required under the Supply of Machinery act 2008 as "when they are first put into service but even the CE consultant we contacted siad why are you doing this as you dont intend to sell or transfer them and the cost is very large £50k+

There is no electrical drawings or technical manuals or evidence that they meet BStandards

what are your views please and has anyone else had this issue

Any recommendations of who to use to do this is also very useful

Roundtuit  
#2 Posted : 12 May 2021 18:00:05(UTC)
Rank: Super forum user
Roundtuit

They would not be UKCA if they are already in use - CE marking would have applied at time of build.

Sounds like you had a poor consultant - if he is watching Paul Skyrme is very knowledgable in this field especially "essential health & safety requirements".

If you have no documents how do you train operators and maintenance personnel to work safely with the equipment as required by PUWER?

https://www.gov.uk/guidance/designated-standards starter for 10

Roundtuit  
#3 Posted : 12 May 2021 18:00:05(UTC)
Rank: Super forum user
Roundtuit

They would not be UKCA if they are already in use - CE marking would have applied at time of build.

Sounds like you had a poor consultant - if he is watching Paul Skyrme is very knowledgable in this field especially "essential health & safety requirements".

If you have no documents how do you train operators and maintenance personnel to work safely with the equipment as required by PUWER?

https://www.gov.uk/guidance/designated-standards starter for 10

ianjones  
#4 Posted : 12 May 2021 18:47:14(UTC)
Rank: Forum user
ianjones

we do have training materials for operators 

we just dont have everything pulled together in a single technical manual

As you say they should have been CE marked but will now be UKCA marked

Edited by user 12 May 2021 18:48:00(UTC)  | Reason: addition

paul.skyrme  
#5 Posted : 12 May 2021 21:01:10(UTC)
Rank: Super forum user
paul.skyrme

Hello ianjones,

Thanks for the vote of support Roundtuit. :)

Your "CE consultant" is wrong.

The law is clear, the MD/SMSR, and all of the guidance, specifically includes machinery for own use.

The procedure is not onerous, and the last step is the CE/UKCA marking.

The legal requirement is for the existing equipment to have been CE marked, and this can be egitimiately done on existing product for a little while yet.

The only differences are the layout of the decaration and the machine plate at this point in time.

It isn't that onerous, and you can do it yourself.  I fail to see how the company built the things without designs?

Your starting point is a stock list of all the parts and all the drawings, the instructions and the data sheets for all the bought in parts.

The difficult bits are really the safety functions and validation there of.

If you want more information, please ask away, this is what I do.

If it gets too much I'll say and you can pay me! ;)

Hope this helps.

thanks 1 user thanked paul.skyrme for this useful post.
peter gotch on 13/05/2021(UTC)
Ian Bell2  
#6 Posted : 17 May 2021 19:37:07(UTC)
Rank: Super forum user
Ian Bell2

Agree with Paul. Your CE consultant is wrong. Gone has the time you could knock something together in the factory workshop and use it.

Even if you have made a machine for your own use, then you are deemed to be placing the machine  'on the market'. It would have needed CE marking, but now its the CA mark. The general principles remain from the Machinery Directive. 

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