MU 2017 November December

64 MACHINERY UPDATE NOVEMBER/DECEMBER 2017 www.machineryupdate.co.uk
Regulations
Look at the complex
world of assemblies
Paul Laidler Taylor
BUSINESS MANAGER DIRECTOR FOR MACHINERY FOR MACHINERY SAFETY SAFTEY AT TÜV AT SÜD TÜV PRODUCT SÜD PRODUCT SERVICE SERVICE
Determining what is seen as an assembly of machines can be tricky and not something that you
want to get wrong in terms of CE marking. Here’s a guide to working through the process
Even though individual
machines may comply
with the Machinery
Directive, when they become
part of an assembly or
production line, which links
two or more machines, it is
this entire assembly that is
then considered to work as
an integral whole and must
therefore be CE marked as a
new machine. Similarly, if
modifications are carried out
that alter the performance
or function of a machine,
or assembly of machines,
this is considered to be
creating an entirely new
machine which warrants
re-certification.
The definition of assemblies
of machinery indicates that
assemblies are arranged
and controlled so that they
function as an integral whole
in order to achieve the same
end. For a group of units of
machinery or partly completed
machinery to be considered
as an assembly of machinery,
all of these criteria must be
fulfilled:
• The constituent units are
assembled together in order
to carry out a common
function, for example,
the production of a given
product;
• the constituent units are
functionally linked in such
a way that the operation
of each unit directly affects
the operation of other
units or of the assembly
as a whole, so that a risk
assessment is necessary
for the whole assembly;
• the constituent units have
a common control system.
A group of machines that
are connected to each other,
but where each machine
functions independently of
the others is not considered
as an assembly of machinery
in the above sense.
Under the Machinery
Directive, the system
integrator/end user that has
created the machine assembly
from separate units is
responsible for ensuring that
the assembly complies with
the Directive’s essential health
and safety requirements.
This is most likely the case,
as it is common practice for
manufacturers of separate
machines to place them
on the market as complete
machinery, which could
operate independently, or as
partly completed machinery
that will then be assembled
into a larger unit.
DECLARATION NEEDED
However, if the organisation
buys the entire assembly from
an original manufacturer,
it must bear the CE marking
and be accompanied by a
Declaration of Conformity.
If machines are placed on the
market as partly completed
machinery, they should
not have the CE marking
applied, but must instead be
accompanied by a Declaration
of Incorporation and the
assembly instructions.
It is then the machinery
system integrator/end user’s
responsibility to ensure
compliance and apply the
CE marking process to the
entire assembly.
DO A RISK ASSESSMENT
If the constituent parts are
functionally linked in such
a way that each unit affects
the operation of the others,
a risk assessment of the
whole assembly is necessary.
The risk assessment
must cover the suitability
Creating a machine assembly
can be a complex process but
guidelines from the HSE can help
of the separate units for the
safe operation of the entire
assembly, and potential
hazards resulting from the
interaction between them.
It must also cover any hazards
that are not covered by the
Declaration of Conformity, the
Declaration of Incorporation
and the assembly instructions
for the individual units.
These three document types
must also be included within
the machine assembly’s
technical file.
The machinery assembly
must be designed and
constructed in such a way that
the stop controls, including the
emergency stop devices, can
stop not only the machinery
itself but also all related
equipment, if its continued
operation may be dangerous.
Where individual machines
making up an installation
are not linked together via
a main control system, this
would not be classed as an
assembly of machines under
the Machinery Directive.
The technical file must
document any modifications
that have been made to
the separate units, when
incorporating them into the
assembly. Also, during its
lifetime, one or more units of
an existing assembly may be
replaced by new ones, or new
units added to an existing
assembly. For such machinery
in service, under regulation 10
of PUWER, the employer must
ensure that the conformity
and safety of the machinery
is maintained throughout its
working life.
CE MARKING PROVISION
When a machine assembly
is first created, or later has
substantial changes made,
a full CE marking and
Provision and Use of Work
Equipment Regulations
(PUWER) assessment must
be completed before that
machine can be returned to
service. Guidelines from
sources such as the Health
and Safety Executive as
well as a thorough
understanding of the
Machinery Directive will
bring clarity to the process.
i For more information contact
W www.tuv-sud.co.uk
TÜV SÜD Product Service
is the PPMA’s technical and
legislative partner