CE Certification - Machinery

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Essential Health & Safety Requirements - Machinery Lifecycle - Manual Handling - Safety Of Control Systems

Here, we will take each section of the Machinery Directives and tease them out in an attempt to expose as many variables as possible.

The original Machinery Directive, 89/392/EEC was the foundation of essential health and safety requirements for work equipment within the European Union. This original Directive has been amended by Council Directives 91/368/EEC, 93/44/EEC and 98/37/EC, each of these subsequent amendments adding new and specific requirements for work equipment.

Some manufacturers, suppliers or users have attempted to use the context of the Directive to fit their own products, when in fact they should be using the spirit of the Directive to identify how close or how far their product is to the essential health and safety requirements as laid down in the Annexes of the Directive. Since the Harmonised Standard EN 292-2: 1991 is literally taken straight from Annex I of the Machinery Directive and that this standard is one of two "A" type standards, it is the author's intention to use EN 292-2: 1991 as a template to compliance with the Machinery Directive. Each section of the Directive will be expanded using references contained in both "B" and "C" class standards as required.

Responsibility for compliance with the Machinery Directive initially rests with the manufacturer or the authorised representative within the EU, i.e. the people first responsible for placing the machinery on the market. If, however, no such compliance exists then the responsibility rests with the person putting the machinery into service, i.e. the user/employer.

The Machinery Directive requires all new equipment installed or put into service after 1 January 1995 to be compliant with the essential health and safety requirements as found in Annex I of the Directive. This includes second-hand equipment first put into service within the European Union that emanates from countries outside of the European Union, e.g. Japan, USA, Korea etc.

Compliance procedures have already been dealt with in Chapter 2, therefore, in this chapter, we will deal with the core of compliance. It should be noted at this point that there is a distinct relationship between the contents of Annex I of the Machinery Directive, EN 292-2: 1991 and national legislation. However, as the reader covers the entire chapter, this relationship will become apparent.

An important comment made by the author in preliminary observations is that the manufacturer is under an obligation to assess the hazards in order to identify all those that apply to his machine and he must then design and construct it taking this assessment into account. This is a clear and unambiguous statement that a risk assessment must be made at the design stage, most probably a Preliminary Hazard Assessment (PHA) and that of the categorisation as required by EN 954-1: 1996.

Scope Of The Directive
The field of application of the Directive is based upon a general definition of the term "machinery" so as to allow the technical development of products. The development of complex installations and the risks they present are of an equivalent nature to "machinery" that their express inclusion in the Directive is justified. The Directive also covers safety components that are placed on the market separately, the safety function of which is declared by the manufacturer or their authorised representative established in the community.

Machinery exhibited at trade fairs and exhibitions do not require CE certification. However, viewers must be informed of its non-compliance and that it cannot be purchased in this condition.
At some time during the machine's lifecycle, the operator decides to short circuit the safety system by easily defeating the guard doors. The machine can now operate with the guard doors open and the operator receives crushing injuries to his/her hands.

The employer may still be liable if he was aware of the bad practice and the employee is most certainly contributory to his injuries, however, the manufacturer's may also be liable since it is their duty to ensure that the machine is designed to operate safely throughout it's lifecycle even under unforeseen abnormal circumstances and that safety interlocks should not be easily bypassed.

JGMA have a vast amount of experience in the CE certification process, including risk assessment, construction of Technical Files, Harmonised Standards and correlating machinery between the various Directives.

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