“Machinery manufacturers often don’t CE-mark machinery correctly, and don’t address essential requirements properly,” said technical adviser at Safe Machine Derek Coulson.
The Machinery Directive stipulates essential health and safety requirements (EHSRs) regarding design and construction. But end users are more likely than manufacturers to be prosecuted under the Provision and Use of Work Equipment Regulations (PUWER), if the equipment is not CE marked correctly, he said.
One of the key requirements of the Machinery Directive is that a technical file should exist for every piece of equipment. Because the file is likely to contain sensitive intellectual property, it is held by the machine manufacturer. However, only health and safety authorities have the right to see the technical file, not the end user.
Plenty of safety checks
“Pre-purchase assessments or CE audits should be undertaken, checking that the technical file does actually exist, checking that the EHSRs and risk assessments have been addressed, that electro-magnetic compatibility has been considered and that the safety-related control system validation report is adequate for the machine,” said Coulson.
End-user checks should also ensure that tests for noise and other issues have been carried out. Given that the customer has no right to see the technical file, all of this information should be listed in the specification, and should be part of the contract, he said.
“Until end users start asking for these details, manufacturers won’t be under any pressure to provide them,” he added.
These regulations have been in force since 1995, but it is surprising how often they are ignored, said Coulson. “When I carry out a CE audit, usually on behalf of an end user, the technical file will often not be there. If it is, the EHSRs will often not have been addressed.”
There are common design flaws which mean that many machines do not conform to standards. “On many of the packaging machines I look at, the electrical panel has not been designed correctly,” said Coulson. “For example, pneumatic and electrical operations should not be housed in the same panel, but I’ve seen machines from major manufacturers which do just that.”
There are further complications when machines – and their control systems – are linked together to create an integrated production line. In such cases, the entire line may require CE marking. “One of the parties involved needs to take responsibility for the CE marking, and this should be determined in the specification,” Coulson warns. “Otherwise, once again, the end user bears that responsibility.”
Coulson, who was formerly with Laidler Associates, delivers seminars on machinery risk assessment, PUWER and other aspects of machine and robot safety on behalf of the Processing & Packaging Machinery Association, and says he is currently planning one on CE audits. “This is the issue I see most companies failing to address,” he said.