One off machinery and h&s advise.

[AdrianH]

To me, CE marking is a way of showing that the machine/equipment has been built taking into account safeguards, regulations etc to provide safe use by operators and that, no one can operate anything without things like interlocks in place, that if it says it can lift X weight, it has been designed as such with a safety margin and the calcs are available as part of the design.

If mains powered and electrical safety is catered for then the motors/switchgear etc should already have CE markings, proper earthing and metal cabinets to house switchgear can minimise any RF issues and I would consider you could self certify a lot.

So if you build to the relevant regs, have used reasonable quality components, have an operator manual, included a service and inspection rutine etc, I can not see why youo could not self certify.

I have a H&S 18001 audit on the 3rd Jan with BSI, would you like me to ask?

Adrian

 

[Kent]

To me, CE marking is a way of showing that the machine/equipment has been built taking into account safeguards, regulations etc to provide safe use by operators and that, no one can operate anything without things like interlocks in place, that if it says it can lift X weight, it has been designed as such with a safety margin and the calcs are available as part of the design.

If mains powered and electrical safety is catered for then the motors/switchgear etc should already have CE markings, proper earthing and metal cabinets to house switchgear can minimise any RF issues and I would consider you could self certify a lot.

So if you build to the relevant regs, have used reasonable quality components, have an operator manual, included a service and inspection rutine etc, I can not see why youo could not self certify.

I have a H&S 18001 audit on the 3rd Jan with BSI, would you like me to ask?

Adrian

Yep please be interesting

 

[dannyp]

a big problem i can see with CE marking. isn't it rather expensive to even just see the regulations ?

 

[AdrianH]

You can download many of the regulations or a precie of them from the HSE website, just takes a bit of finding.

Adrian

 

[AdrianH]

Just to try and report back on this, yes if the equipment comes under the machinery title then it really should have a CE deceleration. But that does not necessarily mean that is an end to it, there are 20 Directives to identify which type of item it is and what course of action can be taken.
From the gov website https://www.gov.uk/guidance/ce-marking#products-that-need-ce-marking

Below is a direct copy from the gov site
How to place a CE marking on a product
Before you place a CE marking on a product, you need to establish which EU New Approach Directives apply to your product. You must not attach a CE marking to a product outside the scope of the directives.

The process you follow depends on the directives that apply to your product.

1. Identify the directive(s) and harmonised standards applicable to the product
There are more than 20 directives setting out the product categories requiring CE marking. The essential requirements that products have to fulfil, for example safety, are created at EU level and are set out in general terms in these directives. Harmonised European standards are issued with reference to the applied directives and express the essential safety requirements in detailed technical terms.

2. Check the product-specific requirements
It is up to you to ensure that your product complies with the essential requirements of the relevant EU legislation. The use of harmonised standards remains voluntary. You may decide to choose other ways to fulfil these essential requirements. If you don’t follow the safety requirements of a standard as it is written you will need to show that your product is as safe, by presenting the relevant documentation.

3. Identify whether an independent conformity assessment is required from a Notified Body
Each directive covering your product specifies whether an authorised third party (Notified Body) must be involved in the conformity assessment procedure necessary for CE marking. This is not obligatory for all products, so it is important to check whether the involvement of a Notified Body is required. These bodies are authorised by national authorities and officially ‘notified’ to the European Commission and listed on the NANDO (New Approach Notified and Designated Organisations) database.

So I have stopped at this point when you have gone through stages 1 to 3 you will hopefully have determined if you can self assess or if you need an external body involved?

From the limited information from the Op's post it was unknown, how helpful the assessor was at the time and would have expected more information to be available, and not just they are condemned because they are not CE marked, but would have liked to have seen comments like this could be a course of action etc or at least information as to which of the 20 directives are applicable. I think if you go back to Ton-up's post there are links there to the HSE site on the Machinery directive and again the possibility of a self assessment is should, i.e. a responsible person.

I was never going to get a more formal response and there was not enough information to provide better, but a general thought that if designed with the regulations for safety in mind, operation, maintenance etc then there could be a positive outcome.

Not sure if it helps but I tried.

Adrian

 

[Ton-up]

Thanks for the help and info Adrian.
Our consultant said 'can't be used without a CE mark' which was totally unhelpful.

The more I look into it though, he was right. No machinery should be put into service without being CE marked. This, as you say can be done yourself.

http://www.cemarkingassociation.co.uk/machinery-built-for-own-use-ce-marking/

 

[fizzy]

Does this mean that you need a CE mark for jigs and press tools etc? I have built a few in the past using air rams or servo actuators.
Yet again a box ticking mentality prevails.............

 

[AdrianH]

If you read the links you get:
CE marking applies to products, ranging from electrical equipment to toys and from civil explosives to medical devices. The full list of these product categories is below:

• active implantable medical devices
• appliances burning gaseous fuels
• cableway installations designed to carry persons
• eco-design of energy related products
• electromagnetic compatibility
• equipment and protective systems intended for use in potentially explosive atmospheres
• explosives for civil uses
• hot-water boilers
• household refrigerators and freezers
• in vitro diagnostic medical devices
• lifts
• low voltage
• machinery
• measuring instruments
• medical devices
• noise emission in the environment
• non-automatic weighing instruments
• personal protective equipment
• pressure equipment
• pyrotechnics
• radio and telecommunications terminal equipment
• recreational craft
• safety of toys
• simple pressure vessels

Have a read on what it means regards machinery.

But if you have built things in the past that includes hydraulics, even if with air systems, things you can get body parts trapped in then I would say yes if used in a commercial operation. Even if built prior to CE marking then you would have been working to Puwer and other standards, so i do not see it as just another box ticking mentality, as you would have been building considering others safety and I see CE marking as a way you are verifying you have done it correctly. If it makes people think on the risks and design accordingly to remove these risks, then it must be good in my mind.

Adrian

 

[dannyp]

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:157:0024:0086:EN:PDF

 

[AdrianH]

Thanks @dannyp I had been trying for some time the links on the HSE website and UK gov over 20mins and never managed the download.

The information seems to start at page 12.

Adrian

 

[dannyp]

i found that Via the HSE website there was a link in another document on there. so very much lucky chance

some of these documents are really not easy reading, that one dosent seem to bad once you get to the information that as you say starts about page 12