Machinery Directive Issues - UKWF

Machinery Directive Issues

CE Marking & Product Safety Consultancy

Nick Williams, Conformance Ltd.

Presentation to the UKWF 14 Oct 2010

Conformance - CE marking and product safety consultancy

Selected topics from the New Machinery Directive

 Relationship with the Low Voltage Directive

 Lifting equipment

  Partly Completed Machinery

 Co-ordinated machinery

The New Machinery Directive


Machinery Safety Directive 2006/42/EC

  Replaces 98/37/EC (which itself replaces 89/392/EC)

  Came into force on 29 December 2009

  No transition period

  Already been amended by 2009/12/EC (“The Pesticides Amendment”)


Machinery Safety Directive – Main changes   Clarifies the scope, and relationship with other directives   Introduces some equipment not previously covered:

  Lifts

  Nail guns

  New requirements for risk assessment and documentation

  Better treatment of Partly Completed Machinery

  No major changes in the technical requirements

Relationship with the LVD


The Low Voltage Directive

  Safety of all electrical equipment operating at voltages between 50V - 1000V ac (75V - 1500V dc)

  Exclusions   Equipment covered by ATEX   Medical devices   R&TTE   Domestic plugs and sockets


Machinery Directive – requirements for electrical equipment:   2006/42/EC Annex 1, pt 1.5.1.

  “Where machinery has an electricity supply, it must be designed, constructed and equipped in such a way that all hazards of an electrical nature are or can be prevented.

  The safety objectives set out in Directive 73/23/EEC shall apply to machinery. However, the obligations concerning conformity assessment and the placing on the market and/or putting into service of machinery with regard to electrical hazards are governed solely by this Directive”.


Machinery Directive exclusions

2006/42/EC Article 1 (2)k:

  electrical and electronic products falling within the following areas, insofar as they are covered by [The Low Voltage Directive]:   household appliances intended for domestic use,   audio and video equipment,   information technology equipment,   ordinary office machinery,   low-voltage switchgear and control gear,   electric motors;


Machinery/LVD relationship

  One or the other but never both

  Most commercial/professional products with moving parts will need to be treated as machinery

  The flexibility which used to be in 98/37/EC for a manufacturer to decide when a product presents mainly electrical risks is no longer present in 2006/42/EC

Lifting equipment


‘machinery’

  Scope (2006/42/EC Article 1)

 Lifting accessories, chains, ropes, webbing

 “an assembly of linked parts or components, at least one of which moves and which are joined together, intended for lifting loads and whose only power source is directly applied human effort;


‘machinery’   Definitions (article 2)

  ‘lifting accessory’ means a component or equipment not attached to the lifting machinery, allowing the load to be held, which is placed between the machinery and the load or on the load itself, or which is intended to constitute an integral part of the load and which is independently placed on the market; slings and their components are also regarded as lifting accessories;

  ‘chains, ropes and webbing’ means chains, ropes and webbing designed and constructed for lifting purposes as part of lifting machinery or lifting accessories;


‘machinery’

YES NO


‘lifting accessory’

YES NO


‘machinery’

? ?

Partly Completed Machinery


Partly completed machinery

  Definition (2006/42/EC Article 2 (g)):   “means an assembly which is almost machinery but which

cannot in itself perform a specific application. A drive system is partly completed machinery. Partly completed machinery is only intended to be incorporated into or assembled with other machinery or other partly completed machinery or equipment, thereby forming machinery to which this Directive applies.”

  If it will undergo a further risk conformity assessment procedure then it is partly completed machinery

  Otherwise, it is complete machinery and must be CE marked


Complete machinery

  CE marked machinery must comply with all EHSRs when placed on the market or brought into service   (machinery made for maker’s own use must be treated the same as

machinery supplied to a customer)

  Instructions must ensure that the end user/assembler puts the machine together in a way which ensures all EHSRs are complied with

  Complete machines supplied as kits need to be CE marked

  A machine lacking only its drive system must be CE marked

  CE mark Declaration of Conformity


Declaration of Incorporation

  “this machine does not comply with the directive and must be made to comply before it is put into service”

  Used to be used as an excuse by manufacturers for not doing anything

  2006/42/EC – now explicitly required to do same type of assessment as for complete machine

  Must provide information on what EHSRs have been addressed, residual risks, information to go on DofI


Declaration of Incorporation   Identification of manufacturer, machinery and responsible person etc, as for

complete machinery

  List of EHSRs which have been applied

  Declaration that the technical documentation is completed in accordance with Annex VII(B)

  Declaration of compliance with other Directives, where applicable

  “an undertaking to transmit, in response to a reasoned request by the national authorities, relevant information on the partly completed machinery. This shall include the method of transmission and shall be without prejudice to the intellectual property rights of the manufacturer of the partly completed machinery”

  Declaration that the machinery is incomplete and must not be put into service, etc.

  Name and address of person authorised to compile the Technical File


Declaration of

Incorporation

Co-ordinated Machinery


Assemblies of machinery

  2006/42/EC Article 2 (a):   “’Machinery’ means… 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”.

  So a production line needs to be assessed as a whole as well as/instead of just as individual machines

  If machines are already CE marked, generally can focus on the interfaces

Key messages


Key messages

  Need to choose between Machinery and LVD   Much equipment which was previously CE marked under the

LVD will now need to be CE marked under the Machinery Directive

  Products which are used to suspend a load are machinery

  Products with moving parts designed to be incorporated into other machinery may need a Declaration of Incorporation rather than a Declaration of Conformity

  Someone needs to take responsibility for the complete installation

THE END

Conformance Ltd. Great Hucklow, Buxton, Derbyshire. England, SK17 8RG tel: +44 1298 873800 fax: +44 1298 873801 http://www.conformance.co.uk CE Marking & Product Safety Consultancy

Machinery Directive Issues - UKWF

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