Page 21 - Industrial Technology January 2020

MACHINE BUILDING

Ensure machines comply

CE/UKCA MARKING

PAUL TAYLOR LOOKS AT SOME OF THE
IMPACTS OF BREXIT ON MACHINE BUILDERS

f you are the project manager that is responsible for machinery
building and safety, it’s vital that you have an understanding of how
Brexit will impact your role. The good news is that after Brexit, the
Iactual process for manufacturing compliant products will have little
effect from a legal perspective as the UK will operate a regulatory regime
that is separate from the EU – just like the rest of the world.
As the EU Directives are transposed into National Law, the UK already
has a legal system in place that applies. There will of course be text IT IS VITAL TO DECIDE
amendments to reflect UK legislative requirements, including the UKCA WHO IS RESPONSIBLE
mark and removal of references to EU directives and the CE marking. While FOR CE/UKCA MARKING
references to ‘harmonised standards’ will change to ‘designated standards’,
the actual standards will remain the same as EU harmonised standards,
and will be carried across as UK designated standards to maintain a single
model, and all products will still need to comply with the essential different colours, leading to confusion. The European Standard allows for ABOUT THE
requirements. However, while the UK remains in the EU, the new UKCA green, white, black or grey for ‘start’ and red, white, black or grey for ‘stop’, AUTHOR
mark for the UK cannot be applied. so even if the supply chain complies with the standard, errors and
Under the current proposal for the UKCA mark, existing UK-based confusion can occur. Paul Taylor is head of
notified bodies will become UK Approved Bodies. So, their actual function Equipment is often designed and installed with no thought as to what industrial products
will remain the same but under a different title. Meanwhile, all relevant happens either upstream or downstream, or who takes the responsibility (UK) at TÜV SÜD. He
certificates that have already been issued for EU Directives before Brexit, for which parts, and who takes responsibility for the final assembly. This has more than a
such as Radio Equipment, Machinery and Marine Equipment, will remain can be exacerbated when equipment is sourced from outside the European decade of hands-on
valid beyond Brexit. Economic Area, or existing equipment is linked to new equipment. experience in the field
When starting a project, it is therefore vital to decide who is going to of machinery safety,
Project management practicalities take the responsibility for the CE/UKCA marking and lay down the ground across a range of
When the Provision and Use of Work Equipment Regulations (PUWER) first rules. Decide what Performance Level the machine will come under, using industry sectors.
came into force in 1992 it included a very simplistic view on CE marking EN ISO 13849 and ensure all suppliers are aware of what is required.
as the end user only had to check that the equipment concerned carried a Make sure they all understand which EN Standards to follow, and that they His areas of expertise
CE Mark. If it did, they were able to presume conformity. PUWER was have copies of the Standards. A good tip is to ask for sample declarations include risk
updated in 1998 and one of the more important but easily overlooked before deciding on suppliers, so that you can check to see if they contain assessment, EMC
changes was that the onus was now put on the end-user to make sure that the correct information. testing, CE marking,
the equipment complies with all relevant legislation such as CE marking. When you issue purchase orders, ensure there is a clause about functional safety,
These changes were re-enforced with further changes in June 2002. CE/UKCA marking which states whose responsibility it is. A solution to this PUWER inspections,
When building machines, or when combining machines to produce an is to use a User Requirement Specification (URS) when purchasing new training and project
assembly of machines, it is easy to get things wrong and end up with a equipment, which will outline your requirements for the equipment management.
project that requires a lot of rework and ends up going over budget or supplier. A URS should include statements such as:
overtime. To this end, it is vital to ensure that the CE/UKCA marking is l The machine must comply with all applicable European and UK At TÜV SÜD, he is
considered from the start. If this isn’t done, common problems that occur legislation (list all applicable directives) responsible for a team
include: l Euro-norm standards should be used to achieve compliance with the of engineers who have
l Equipment being installed before a final layout is agreed so that essential safety requirements of all applicable directives extensive experience
machines have to be moved and rework is required. l Documentary evidence demonstrating compliance with all applicable in electrical and
l Consideration not given to a safety related control system at the start directives will be required mechanical machinery
leads to a number of problems when linking different machines with l A Declaration of Conformity will be required inspection, offering
different performance levels. l A CE/UKCA marking will be applied to the machine, preferably on the specialist health &
l Not considering control system functionality so that feed conveyors are maker’s nameplate safety advice to
not stopped when a process is stopped, resulting in damaged products at l A full operation and maintenance manual that complies with EHSR enable clients to
best and injury at worst. 1.7.4 of the Machinery Directive will be required reach their
l Machinery that is not inspected before installation subsequently reveal Before accepting and paying for any machines, check that they meet compliance goals.
non-compliances, resulting in disagreements about who pays to put it right the requirements of the order and also that they conform to the Machinery
- the supplier, the contractor or the user. Directive. A pre-purchase audit is a useful system that can help
l Control colours not being agreed means that different suppliers may use machinery buyers ensure that equipment is both safe and correct.

MORE INFORMATION: www.tuv-sud.co.uk • info@tuv-sud.co.uk • Tel: 01489 558100

January 2020 •INDUSTRIAL TECHNOLOGY 21