Derek Coulson, technical advisor, Safe Machine Ltd
CE (Conformité Européenne) marking of machinery has been with us since 1993, so it is of some concern that many machinery users and manufacturers still do not do it properly. The original Machinery Directive was significantly modified at the end of 2009. Machinery supplied since then should comply with the current Machinery Directive 2006/42/EC, which defines machinery as “an assembly, fitted with or intended to be fitted with a drive system other than directly applied human or animal effort, consisting of linked parts or components, at least one of which moves, and which are joined together for a specific application”.
It also includes “assemblies of machinery … or partly completed machinery … which, in order to achieve the same end, are arranged and controlled so that they function as an integral whole”.
It goes on to define partly completed machinery as “an assembly that is almost machinery, but which cannot in itself perform a specific application. Partly completed machinery is only intended to be incorporated into or assembled with other machinery or other partly completed machinery or equipment, forming machinery to which this Directive applies”. The difference is that machinery must carry CE marking, whereas partly completed machinery must not.
A robot is a partly completed machine, as it has to be integrated into other machinery to carry out its functions. The hazards need to be addressed by the integrator, rather than by the robot manufacturer. Something like a conveyor could be either a machine, or a partly completed machine. If it is supplied with controls and just needs connecting to a power source, then it is a machine and should carry CE marking. If it is controlled by the system into which it is being incorporated, it should not carry the CE marking.
A standalone machine that works on its own, does not require any other equipment to feed it and does not need any other communication with other equipment should carry CE marking. It should be supplied with a Declaration of Conformity and an instruction manual.
If a machine is purchased that cannot work on its own, needs other equipment to work with it or needs inter-connection, it should be considered as partly completed machinery. CE marking should not be applied and a Declaration of Incorporation and assembly instructions should be supplied. The equipment must not be used until the complex assembly of machines has been CE marked and is safe.
End users need to understand what their responsibilities are when ordering machines, as they have a duty to ensure that the equipment being supplied has been CE marked correctly. It is not enough to assume the manufacturer is doing it correctly; the end user should be checking that the equipment is safe and the documentation is correct.
Under the Provision and Use of Work Equipment Regulations (PUWER), Regulation 10 specifies: “Every employer shall ensure that an item of work equipment conforms at all times with any essential requirements … in which these Regulations apply.”