CE marking – Complex assemblies
Original article date: July 1999
How do you CE mark a production line that is made up of many linked machines? DEREK COULSON of Laidler Associates explains.
A complex assembly can be defined as a number of machines that are generally capable of functioning when linked together to form a single production line, although they could be capable of working independently. Whilst the machines are interdependent, each may require a CE mark. When they are joined as a single line, that will also require CE marking.
A complex assembly can involve anything from two to a thousand machines. A good example of a complex assembly is one of British Steel’s production lines, which is half a mile long.
When setting up and installing a complex assembly it is vital that someone takes responsibility for CE marking the complex assembly. This usually falls to: the purchaser of the machinery; the primary contractor (generally the supplier of the bulk of the machines); or a project manager.
Laidler Associates recently teamed up with David S Smith Liquid Packaging to assist with CE marking a complex assembly based on premise that David S Smith was the primary contractor. The contract involved setting up a new wine box filling line at a plant near Avignon owned by leading French bottlers Les Chais Beaucairois (LCB).
David S Smith has a lot of experience of CE marking individual machines but rarely installs a complete line. In this case, although all the machines carried individual CE marking from their suppliers, Laidler Associates was asked to provide project management and expert support for a complex assembly which covered six main pieces of equipment linked with various transfer systems.
During the exercise Laidler worked alongside David S Smith’s engineers and was able to provide hands-on training as the new line was pieced together.
The procedure adopted for this exercise was:
- Produce a technical file for the line, checking the original Declarations of Conformity or Incorporation.
- Check that each machine conformed, and was in fact safe, (under Section 10 of PUWER ‘98 the responsibility is also placed on the purchaser to check conformity).
- Ensure compliance with the Essential Health and Safety Requirement and carry out risk assessments in accordance with EN 1050, to ensure the machines were safely linked and that, in doing so, no new hazards had been created.
- Examine pneumatic, electrical and line drawings of the assembly.
- Check to ensure that machinery complied with the EMC and Low Voltage Directives.
Laidler was able to augment the exercise and its training content by using its own CE marking and Risk Assessment software. Once the line was complete and operational a Declaration of Conformity was issued to LCB by David S Smith.
Two important points relating to complex assemblies are that any non-CE marked equipment added to a line carrying CE marking must comply to a similar standard of safety as the new machines; any linking of old and new equipment must comply with PUWER ‘98, and the line may require CE marking. In these instances a decision will need to be made to assess any change to the actual process and whether new CE marking is necessary. There are a number of possibilities:
- The contractor uses new machinery to construct the assembly. He may purchase or import machinery which conforms to the Directive and bears the CE mark, or he may purchase or import machinery not bearing the CE mark. The machinery will be accompanied by one of the declarations referred to in Section A and B of Annex ll.
The contractor is responsible for the procedures relating to the assembly: ensuring that the CE mark is positioned to make clear that it refers to the assembly. It is also advisable that all necessary steps are taken to ensure that technical files relating to the equipment exist. - The contractor may be involved several years after the machinery has been put into service; for example, when modernising a production line. The original machinery may or may not bear the CE mark (depending on whether or not it pre-dates the implementation of the Directive. The contract must endeavour to comply with the Directive and must provide the technical file, affix the CE mark on the assembly and draw up the EC declaration of conformity.
- A component machine within an assembly is replaced. If the function or performance of the assembly is not thereby modified, this operation can be treated as a repair, even if the replacement machine is of a different make, so no new CE mark is applied to the machine or the assembly.
Background to Laidler Associates
Laidler Associates provides machinery safety system-related training, advisory and project management services. Areas of expertise include the Machinery, Low Voltage and EMC ‘CE marking directives’, Puwer and S2 inspections, as well as a comprehensive service to help manufacturing businesses deal with the safety and production aspects of the Year 2000 problem. To discuss your problems in any of these areas, Derek Coulson and his colleagues may be contacted on 01642 345637 or visit the web site atwww.laidler.co.uk
July 1999