CE MARKING OF MACHINERY
PROVISION & USE OF WORK EQUIPMENT
MACHINERY SAFETY TRAINING
The CE marking or UK CA marking shows that the manufacturer is declaring conformity with all Directives and UK Regulations relating to that product. This is the ‘New Approach’ which is intended to reduce barriers to trade within the EU.
In December 2019 a new UK Government was formed that is now supporting the leaving of the UK from the EU by the end of January 2020. There are negotiations to determine what sort of relationship there will be with the EU. These talks are due to end by December 31st 2020, at which point there should be some clarity on whether UK CA Marking will be required. Until then, CE Marking is still required, UK CA Marking is not.
The Directives are brought into each European countries legal system, in the UK as Regulations. It is a criminal offence not to comply, punishable by fines or imprisonment.
It is the manufacturers responsibility to ensure that machinery complies with the Essential Requirements of all Directives that may apply. However, there are some exemptions, see the Directive text.
Practically, what this means is that there must be a Technical File available for the machine, or assembly of machines. This should include how the equipment meets the Essential Requirements of the Directives that apply. Risk Assessments, test results, detailed drawings and calculations demonstrating that the equipment is safe should also be recorded. There should also be a copy of the Instructions and the Declaration of Conformity, or Incorporation if a partly completed machine.
Safe Machine Ltd’s machinery safety consultants can carry out design reviews and risk assessments at an early stage. We therefore assess the machine and documentation and provide guidance as to what, if any modifications are required. Safe Machine Ltd. can compile the Technical File, address the EHSR’s and provide a list of Standards to use.
Sometimes Safe Machine Ltd. will act as the Responsible Person and sign a Declaration. This is generally for complex assemblies or one-off machines for a specific purpose, where there is no recognised manufacturer.
CE or UK CA Marking applies to all new machinery, new assemblies of machines (even if existing machines). It also applies to machinery built for in-house use, interchangeable equipment and possibly modified machinery.
Member States must presume that products bearing the CE marking comply with the provisions of all applicable directives. Member States may not prohibit, restrict or impede the placing on the market and putting into service in their territory of products bearing the CE marking, unless the provisions relating to CE marking are incorrectly applied. UK applies the same requirement to UK CA Marking.
There is a requirement for companies to have the name of the person to ‘compile’ the Technical File listed on the Declaration. This person must therefore be able to provide a copy of the relevant parts of the Technical File following a request from relevant Authorities. This must be a person in the EU for the EEA, and a person in the UK for the UK. Safe Machine Ltd. will act as the person to compile Technical Files in the UK. Hold Tech Files Ltd. can act as the person in the EU. Hold Tech Files is based in the Republic of Ireland.
Safe Machine Ltd. can also assist with the production of technical files, risk assessment and any testing that may be required. Our machinery safety consultants carry out PUWER assessments, which should be done before the machine is put into service.
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