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Creating Machinery/Equipment in-house??

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Safe&Sound
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Creating Machinery/Equipment in-house??

Post by Safe&Sound »

Hi all,

This may sound rather complicated so apologies in advance.

A company I support builds in house equipment to use on their manufacturing lines (built by the engineers). Equipment can range from rollers built directly onto the conveyor systems to 'press' packaging or free standing press stations that are operated by the employees to press the product into place.

A can of worms has opened as the in-house equipment does not have CE marks nor technical files as the assumption in the past was that it was built for their own use and not to supply onto the market.

Im sitting down with them in the next following weeks to discuss the process further to see whether we can actually get an external company to build the equipment they need OR to develop a procedure that they follow in accordance to the Supply of Machinery (Safety) Regulations and the European Directive for Machinery.

My question is; if a procedure is developed and followed in accordance to the relevant regulations, can the company CE mark their own built equipment as long as it meets the standards? If so does anyone know of any checklists around or further guidance to help achieve compliancy?

Appreciate any thoughts and feedback on this as its something I want to get my teeth into and understand a lot more about.

Thank you in advance.
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Re: Creating Machinery/Equipment in-house??

Post by stephen1974 »

One for the lawyer types amongst us me thinks.

However, as you are interested in learning more about it, have you looked at the guidance documents for the various regulations. They can clarify what is and isnt required and may have a list of exemptions that apply.
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Re: Creating Machinery/Equipment in-house??

Post by Blackstone »

Interesting one...

So i understand a bit about the Machinery Directive and CE marking of the equipment.

Something im not quite getting is, whats the need to add in extra procedures and processes for a bit of equipment that is never going to market or be sold?
As long as the equipment is properly tested and commissioned, safe, training given, SSoW and RA in place, why does it need a CE mark?

Yes they can CE mark the equipment, just don't see the need (there may well be one of course).

Glen
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Re: Creating Machinery/Equipment in-house??

Post by Safe&Sound »

Hi Glen,

Thanks for your comments. This may be my interpretation of the HSE guidelines as I have read it that you must CE mark your in-house built machinery if it falls within the Machinery directive;
It depends on the product but you must CE mark work equipment that comes under the Machinery Directive and make sure it meets all of its essential health and safety requirements - even if it is only for your own use and you have no intention of supplying it to other parties. - HSE
I agree with you in terms of if they ensure the equipment is tested, safe and has a SSoW and RA produced then is it a case of the responsible person reviewing the equipment, SSoW, Risk Assessments and safety measures (controls) before simply signing a document to say it conforms with the machinery directive and attaching a CE sticker??
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Re: Creating Machinery/Equipment in-house??

Post by Blackstone »

Safe&Sound,

Do you have a link to that article?
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Re: Creating Machinery/Equipment in-house??

Post by Safe&Sound »

Blackstone wrote: Wed May 29, 2019 3:19 pm Safe&Sound,

Do you have a link to that article?
HSE (last question on page: http://www.hse.gov.uk/work-equipment-ma ... faq-ce.htm

Also a bit here: http://www.hse.gov.uk/work-equipment-ma ... hinery.htm
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Re: Creating Machinery/Equipment in-house??

Post by Godscrasher »

Hi,

I'm happy to help here as I've experience in this field and have sat many machinery safety course up to an advanced level (CMSE next).

If they are manufacturing the conveyor belts they will fall under the description matched up by the machinery directive as the will have a drive motor on one end (unless they're free rolling gravity ones)?

Form your post I can gather that they will be driven by a motor. For conveyors they will need to conform to the machinery directive and meet the essential requirements. A risk assessment will need produced for your part A standards (En 12100), then your part B general safety requirements ie: en 13857, 60210 and other associated standards. Once it all complies you'll be able to self certify the equipment. Don't forget your technical file. They'll also need to ensure the control panel and system is build to standard Is this possibly the case with them?

If they are building presses again it's going to fall under the machinery directive. This can get quite a complex area for some and it certainly seems that they are building without thinking about legislation (PUWER mainly as reg 10 covers conformity).

Advise them that as it's fitted with a drive system, they need to first go to the machinery directive (or follow the Supply of Machinery Regs). It doesn't matter that they're building it in house, they'll need to CE mark it as they are 'putting it on the market' when first using it.

The only exception to this is if there are experiments in laboratories etc, but it doesn't seem he case.

Happy to help.
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