PM Group’s senior engineers Pat Swords and Margaret Doran presented a poster and associated technical paper at the Institution of Chemical Engineers ‘Hazards 26’ conference in Edinburgh, which took place last month. The subject matter, ‘CE Marking; ATEX, Machinery Directive, etc – How to Get it Right’, arose out of a recognition that in the process industry sector in general, there was a failure to identify where the EU’s CE marking compliance requirements arose and to develop a practical strategy to implement the legally required ‘essential health and safety requirements’.
The full 12-page technical paper is available on the PM Group’s website, so it is not intended to replicate the content here, but instead introduce the subject matter and its relevance.
For starters, what is CE marking and how is it relevant to implementing an engineering project? The EU’s ‘New Approach’ to standardisation, associated conformity assessment and CE marking now runs to some 28 directives and five regulations. These ‘New Approach’ directives define essential requirements related to health, safety and environmental issues.
Products must meet these requirements in order to be placed on the European market. As such, then, the traditional process plant now has additional compliance requirements, primarily associated with the Machinery Directive, the Pressure Equipment Directive and the ATEX (Explosive Atmospheres) ‘equipment’ Directive.
These ‘essential health and safety requirements’ are supported by a comprehensive set of international and European standards, which define the state of the art with regard to machinery safety, equipment for potentially explosive atmospheres, etc. In Europe, the manufacturer or its authorised representative is required to undergo a specific conformity procedure and CE mark the equipment. Outside of the European Economic Area, no such CE marking is required, but under the general duty of care, compliance with the same recognised standards and state of the art would be expected.
Indeed, as part of World Trade Organisation (WTO) agreements, there is an increasing harmonisation of technical standards, although the manner in which they are implemented depends on the legal jurisdiction. For instance, in Russia and the associated Eurasian Customs Union, there is a product conformity system, previously called GOST, but now being replaced by the EAC mark, i.e. ‘Eurasian Conformity’: Different marking to our familiar CE, but same technical standards supporting the necessary compliance!
In Germany, if we consider the accident statistics for 2013, there were 78 fatalities and 2,252 new pensions, the latter resulting from circumstances where it was not possible to rehabilitate injuries with respect to a full return to employment. The message is clear: deficiencies in machinery safety, even in a country which would be considered ‘best in class’, are having a significant impact. Therefore, CE compliance is an integral part of PM Group’s general duty of care, as an international engineering design and construction management company.